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General	Steel	Industries	(GSI)	SEC-00105	Co-Petitioner

Dan	McKeel’s	Critique	of	Appendix	BB	Rev	1	(6/6/14)

Daniel	W.	McKeel,	Jr.,	M.D.

(©	July	2014	- version	1.5,	7.15.14)

Introduction

This	document	is	a	scientific	critique	of	Appendix	BB	Rev	1	(hereafter	abbreviated	

“AppBBr1”)	dated	6/6/14	by	David	Allen	of	DCAS/NIOSH.	SEC	Counselor	Josh	

Kinman	e-mailed	the	PA-cleared	version	to	Dan	McKeel	on	June	25,	2014.	Mr.	

Kinman	noted	he	had	sent	a	copy	to	“one	other”	person	(not	named).	Presumably	

this	person	was the	primary	GSI	SEC-00105	petitioner,	Patricia	(formerly	Coggins)	

Jeske.	As	of	this	date,	Mrs.	Jeske	has	not	confirmed	receipt	to	McKeel	of	receiving	a	

copy	of	AppBBr1.

The	original	AppBr1	document	sent	to	McKeel	was	a	38-page	PDF	file he	converted	

to	plain	text	and	Word	.doc	formats.	Tables	and	diagrams	were	captured	using	the	

Apple	Grab utility	and	then	copied	and	pasted	into	the	manuscript	without	

alteration.	

The	original	material	is	reproduced	as	(original)11.5	pt.	New	Times	Roman	text	and	

McKeel’s	commentary	is	reproduced	using	the	Microsoft	Word (Office	2011 for	Mac)	

Cambria	12	pt.	font. The	final,	distributed	Word	.doc	file	was	converted	to	PDF.	

Executive	Overview of	This	Critique

The	parent	document	to	AppBBr1,	Battelle	TBD-6000,	was	released on	June	11,	

2011.	The	38-page	AppBBr1	by	Dave	Allen	of	DCAS	(NIOSH)	is	dated	June	6,	2014.	

The	preceding	version	of	Appendix	BB,	Rev	0,	by	Dave	Allen	and	Sam	Glover	of	DCAS	

(NIOSH),	is	12 pages	long	and	is	dated	June	25,	2007,	almost	seven	years earlier.	

NIOSH	had	no	GSI	site	monitoring	data	at	this	time.	Compared	to	other	EEOICPA	

sites,	this	is	a	very	prolonged	interval	between	major	TBD	revisions.	All	but	four	of	

the	NIOSH	dose	reconstructions	completed	for	the	GSI	AWE	site	to	date	have	been	

based	on	AppBBr0.	The	four	earlier	DRs	that	were	not	based	on	AppBBr0	are	

covered	in	GSI	PER-24.

The	Dose	Reconstruction	standing	Subcommittee	(DRSC)	of	the	ABRWH	under	its	

chairmen	Mark	Griffon	and	David	Kotelchuck	has steadfastly	refused	to	review	any	

GSI	completed DRs.	Approximately	five	GSI	cases	were	scheduled	to	be	reviewed,	

including	two	GSI	DRs	that	SC&A	identified	as	having	very	flawed	NIOSH	DR	

methodology.	The	DRSC	chair	wrote	McKeel	earlier	this	year	to	say	no	GSI	cases	

would	be	reviewed	until	AppBBr0	could be revised. That	happened	6/6/14.

AppBBr1,	similar	to	the	predecessor	document,	has	many	serious	scientific	flaws.	

Mr.	Allen	ignores	vast	amounts	of	new,	informative	DR	and	SEC	data	that	has	been	
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provided	by	the	GSI	SEC-105	petitioners,	site	experts	and	workers.	The	largely	

ignored	material	includes	53	white	papers	by	SEC-00105	co-petitioner	McKeel.

Detailed	Critical	Analysis:	Allen	DCAS	AppBBr1	Paper

[Page	4	of	38]

BB.1	Introduction	

This	document	serves	as	an	appendix	to	Battelle-TBD-6000,	Site	Profiles	for	Atomic	

Weapons	Employers	that	Worked	Uranium	Metals.	This	appendix	describes	the	

results	of	document	research	specific	to	this	site.	Where	specific	information	is	
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lacking,	research	into	similar	facilities	described	in	the	body	of	this	Site	Profile	is	

used.

MCKEEL	COMMENT	to	BB.1	Introduction:	The	parent	Battelle	TBD-6000	

document	should	be	identified	by	Rev	0	or	1	and	by	the	release	date	in	2006	

(Rev	0)	or	2011	(Rev	1).	The	meaning	of	the	term	“document	research”	is	not	

clear.	There	should	be	allusion	to	the	previous	Appendix	BB	version,	Rev	0	

(June	2007)	to	make	the	context	of	this	Rev	1	version	entirely	clear	and	

transparent.	It	would	be	better	to	include	a	statement	as	to	why	this	Rev	1	

document	was	necessary. This	is pertinent	background information.

BB.2 Site Description 

General Steel Industries (GSI) performed quality control work for the Atomic Energy 

Commission (AEC) from October 1952 until June 1966. Utilizing two 25 MeV betatron 

machines, it performed x-rays on uranium metal of various forms including uranium 

ingots and betatron slices to detect metallurgical flaws for the Mallinckrodt Chemical 

Company (DOE Web Site). The x-ray films were processed, but not interpreted, at 

General Steel Industries. The facility is located at 1417 State Street in southwest Granite 

City, Illinois, northeast of St. Louis, Missouri, east of the Mississippi River. The use of 

the facility for these services was on an as-needed basis controlled by purchase orders 

with limits but no indication of actual frequency or duration (ORNL 1990).

MCKEEL	COMMENT	to	BB.2 Site Description: This brief paragraph does not 

capture the scope of the work performed at GSI from Oct. 1, 1952 through 1973. 

Such an expanded site description is necessary because part of the exposures were 

due to Betatron nondestructive testing (NDT) on non-uranium metal (primarily 

steel) castings. The Betatron would be more correctly classified as a type of electron 

particle accelerator developed by Donald Kerst in 1939. The term used “Betatron 

machine” is imprecise (too general). The allusion to “(DOE website)” is also 

meaningless without providing a URL. There are multiple DOE websites, actually.

Also, one doesn’t “perform x-rays”, one carries out nondestructive testing (NDT) 

radiography that includes the production of x-ray films as an end product. Thus, 

more precisely, the two GSI Allis-Chalmers 24 and 25 Mev betatrons were used to 

examine uranium metal and steel castings by generating penetrating x-ray films of 

the surfaces and deep structures using novel NDT Betatron radiography methods. 

BB.2.1 Site Activities 

During the late 1950s and early 1960s, General Steel Industries used a betatron to x-ray 

uranium metal for the AEC under purchase orders issued by Mallinckrodt Chemical 

Works. Purchase orders were issued by the Uranium Division, Mallinckrodt Chemical 

Works, from February 1958 through June 1966, first to General Steel Castings 

Corporation and later (July 14, 1961 and after) to General Steel Industries, Inc., at the 

same address. The uranium to be x-rayed was owned by the AEC and provided by 

Mallinckrodt (DOE 1991).
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MCKEEL	COMMENT	to	BB.2.1 Site Activities: 

1.	The	reference	“(DOE	1991)”	is	so	imprecise	to	be	meaningless.	What	

reference	document	is	being	referred	to	should	be	spelled	out	with	author,	

title,	report/SRDB number	and	date,	and	specific	page/s	being	referred	to.	

Preferably	a	URL	link	to	the	report	would	be	provided.

2.	The	fact	that	GSI	began	Betatron	R&D	work	with	the	AEC	using	MCW	

uranium	billets	and	a	uranium	shield	furnished	by	MCW	as	early	as	October	1,	

1952	is	well	established	by	both	NIOSH	and	McKeel	documentation.	Thus,	the	

phrase	in	the	first	sentence	“during	the	late	1950s.” is	incorrect;	the	Betatron	

AEC-MCW	uranium	work	began	in	the	early	1950s.	This	error	needs	to	be	

corrected.	The	phrase	is	true	based	on	work	done	under	MCW	purchase	

orders	that	DOE	provided	to	NIOSH	for	1958	through	1966.	The	text	should	

state	that	NIOSH	was	unable	to	locate	any	MCW	Uranium	Division	purchase	

orders	earlier	than	1958	and	what	efforts	were	made	to	retrieve	them.

3.	Allen	here	omits	the	key	fact	that	MCW	purchase	orders	covering	the	GSI	

uranium	work	for	1952	through	1958	were	never	located	by	DCAS/NIOSH	or	

anyone.	Yet	the	fact	that	the	GSI	Betatron	was	in	use during	the	last	quarter of	

1952	for	AEC-MCW	uranium	nondestructive	imaging	R&D	is	indisputable	from	

the	three	AEC	operational	reports	furnished	to	DOL	by	McKeel	(November	and	

December	reports)	and	by	NIOSH	two	days	later	for	October	1952.

4.	To	be	fully	accurate	about	the	site	description,	it	should	be	noted	the	

original	GSI	1417	State	Street,	Granite	City,	IL,	A-C	24	Mev	Betatron	and	the	

facility	it	was	housed	in	was	owned	by	the	“US	government.”	The	GSI	site	

expert	and	SEC	co-petitioner	furnished	this	information	to	Dave	Allen and	the	

TBD-6000	WG	based	on	official	GSI	Board	of	Directors	minutes	they	retrieved	

from	the	Missouri	Historical	Society	on	Lindell	Blvd.	in	St.	Louis,	Missouri.	We	

also	have	newspaper	evidence	that	the	Chicago	District	of	the	US	Army	Corps	

of	Engineers	built	the	original	(“old”)	Betatron	building	and	installed	the	A-C	

24	Mev	Betatron	during	1951.	The	news	accounts	stae	the	first	GSI	betatron	

was	put	into	operation	Jan.	14,	1952.	Allen	mentions	none	of	this	information.

BB.2.2	Frequency	of	uranium	X-rays	

General Steel Industries work with uranium was performed under purchase orders with 

Mallinckrodt Chemical Works starting in March of 1958. These purchases orders cover 

the time period March 1, 1958 through June 30, 1966 (Mallinckrodt 1958-1965). These 

purchase orders indicate that the work was to “X-ray material as requested by 

Mallinckrodt...” They also contained “Betatron labor charges, including operation and 

maintenance and all overhead shall be billed at $16.00 per hour.” The last purchase order 

covering the period of July 1, 1965 to June 30, 1966 indicated a billing rate of $35.00 per 

hour. The purchase orders also indicated that the work was not to exceed a set cost. The 
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first purchase order, covering the period March 1, 1958 to June 30, 1958 stipulated a 

monthly limit of $500. That purchase order was extended to October 31, 1958 and added 

$1800 to the total limit (an additional $450 per month). A new purchase order covered 

the period November 1, 1958 to June 30, 1959 and stipulated a monthly limit of $450 and 

a total limit of $3600 (equal to $450 per month). The next purchase order covered July 1, 

1959 to June 30, 1960 and stipulated a monthly limit of $450 with a total limit of $7200. 

It should be noted that the total limit does not add up to 12 months at the monthly limit. 

This is the only purchase order with this conflict. Since these are	limits	and	not	

estimates, the most limiting of the two values will be used in this appendix which is 

consistent with purchase orders written both before and after this one.

[Page	5	of	38]

From that point on, the purchases orders were written annually covering a period of July 1 to 

June 30 of the next year. All but the last order stipulated a billing rate of $16 per hour. The 

purchase order starting in 1960 stipulated no total limit. Only a monthly limit of $450 per 

month was specified. After that, only a total limit was specified. These limits were $7000 for 

the purchase order starting in 1961, $2000 for the purchase order starting in 1962, and $450 

for each of the remaining purchase orders. From this information, it is possible to determine 

the maximum hours per month that General Steel Industries spent on operations, maintenance 

and overhead associated with x-raying uranium for Mallinckrodt Chemical Works. A 

summary of that information is contained in Table 1.

These estimated hours are considered the maximum hours that could have been spent xraying uranium. These are considered maximum because the purchase orders set these 

costs as a limit. There is no indication how much of the available funds were actually 

used. Also the cost was to include maintenance down time and overhead as well as the 

cost of film. 

For the remainder of the year, it is assumed that various alloys of steel were x-rayed. The 

operators reported that overtime was very frequent. Operators indicated that an 8 hour 

work day was “not the norm”. They indicated overtime was frequent (Simmons Cooper 

2006). During one meeting, workers estimated that they worked an average of 65 hours 

per week (Minutes 2007). This document will assume workers spent 65 hours per week 
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on average for 50 weeks per year for a total of 3250 hours per year. This equates to an 

average of 406.25 eight hour shifts per year. From the information contained in Table 1 

the number of hours for each calendar year can be calculated and expressed as a number 

of shifts per year GSI employees worked with uranium and steel. The covered period for 

GSI starts 10/1/1952 while the first purchase order found starts on 3/1/1958. The time 

period prior to March 1958 is considered to be equal to the highest monthly rate in Table 

1. Table 2 lists the uranium work hours and the total number of eight hour shifts per year 

associated with uranium or steel.

MCKEEL	COMMENT	BB.2.2	Frequency	of	uranium	X-rays:	The	GSI	SEC	copetitioner	and	site	expert	dispute	Dave	Allen	and	DCAS/NIOSH’s	assertion	as	

to	the	exact	reasons	GSI	was	hired	by	MCW	and	the	AEC	to	examine	uranium	

metal.	The	phrase	Allen	uses:	“X-ray material as requested by Mallinckrodt...” fails	

to	capture	the	complete	story.	We	believe	there	were	probably	three	purposes	

for	the	uranium	NDT	inspections:	(1)	for	the	period	10/1/52	through	

12/31/52,	DOE	operational	reports	clearly	indicate	GSI	was	partnering	with	

MCW	and	AEC	on	experimental	work	to	improve	the	quality	of	x-ray	imaging	

of	uranium	using	a	special	uranium	shield	built	at	MCW,	(2)	for	dingots,	the	

purpose	of	NDT	x-ray	radiography	was	to	identify	the	interface	between	the	

outer	crust	(slag,	mg-fluoride)	and	the	inner	pure	uranium	metal	as	an	aide	to	

machining	on	a	lathe1,	and	(3)	for	betatron	slices,	perhaps	the	main	purpose	of	

Betatron	radiography	to	examine	the	interior	of	the	metal	for	fractures,	

casting	voids	and	other	imperfections.	Again,	Mr.	Allen’s	site	activities	

description	is	so	truncated	and	imprecise	that	it	fails	to	adequately	serve	the	

central	purpose	of	technical	dose	reconstruction	TBD	guidance.

•	The	last	sentence	on	page	5	indicates	that	AppBBr1	will	use	a	65	hour	

average	work	week	(3250	hours	per	year).	Allen	needs	to	make	explicit	this	is	

a	major	change from	AppBBr0	(2007),	where	the	average	GSI	work	week	was	

designated	to	be	only	46	hours.	Because	of	this	fact	alone,	all	denied	GSI	part	B	

claims	with	DRs	completed	under	AppBBr0	(2007)	must	be	reopened	and	

reworked,	and	a	PER has	to	be	issued	to	allow	this	to	happen.	DCAS	Director	

Hinnefeld	confirmed	in	a	recent	e-mail	to	Dan	McKeel	that	a	GSI	PER	based	on	

TBD-6000	Rev	1	(2011)	and	AppBBr1	would	be	issued	as	a	“high	priority”	

activity.

It	should	also	be	noted	that	NIOSH	has	no	documentation	other	than	1958	

through	1966	MCW-AEC	purchase	orders	to	confirm	the	amount	of	uranium	

source	term	material	used	at	GSI	during	the	operational	period	(10/1/52	

through	June	30,	1966).	There	are	no	shot	records,	no	shipping	manifests,	no	

																																																							 1 The	GSI	SEC-00105	co-petitioner	and	site	expert	provided	quotes	from	the	“Fuel	for	the	

Atomic	Age”	report	by	the	MCW	President,	Harold	Thayer,	testifying	that	radiography	was	was	

done	to	assist	maching	the	uranium	dingots	by	MCW.	We	thus	dispute	SC&A	and	Bill	Thurber’s	

opinion	that	x-ray	inspections	were	not	necessary	to define	the	slag	(crust)	and	uranium	

dingot	interface.	Written	expert	knowledge	testimony	by	the	President	of	MCW	should	be	

afforded	the	greatest	credence.
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documentation	at	all	for	the	years	1952	through	1958	before	the	first	

Purchase	order.	There	are	DOE	operational	reports	which	describe	the	1952	

uranium	R&D	work	GSI	performed	with	MCW	and	the	AEC	qualitatively but	not	

quantitatively.	Allen	ignores	these	missing GSI	uranium	source	term	data	and	

assumes,	without	any	valid	scientific	rationale,	that	it	was	acceptable to	back	

extrapolate	the	uranium	source	term	for	1952-1958	using	1958	through	mid1966	MCW	purchase	orders.	The	GSI	SEC	co-petitioner	and	main	site	expert	

strongly	disagree	with	that	assumption we	equate	with irresponsible	and	

unscientific	speculation	which	we	believe	is	scientifically	indefensible.

I	need	to	point	out	again	the	1952	Betatron	R&D	work	with	MCW	uranium	

differed	markedly	from	the	MCW	NDT	production	work	that	was	covered	by	

the	1958	through	1966	purchase	orders,	a	fact	that	Mr.	Allen	again	ignores.

[Page 6 of 38]

BB.3 Occupational Medical Dose 

No detailed information regarding occupational medical dose was found in any of the site 

research or telephone interviews. Information to be used in dose reconstructions, for 

which no specific information is available, is provided in ORAUT-OTIB-0006, the 

technical information bulletin covering diagnostic x-ray procedures. 

MCKEEL	COMMENT	to	BB.3	Occupational	Medical	Dose:	I	believe	this	

boilerplate	language	in	many	NIOSH	TBDs	is	highly	misleading	for	several	

reasons.	First,	the	CATI	interviews	should	have	contained	some	information	

about	employment,	hiring and	termination	x-rays.	In	addition,	the	GSI	site	
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expert	provided	the	TBD-6000	workgroup	with	documentation	from	a	1974	

GSA	auction	of	GSI	equipment	which	clearly	documented	three	portable	250	

Kvp	x-ray	units were	for	sale.	One	of	these	was	a	medical x-ray	unit	and	the	

model	and	manufacturer	and	nominal	output	were	known.	Thus,	a	medical	

x-ray	source	term	external	dose	for	GSI	employees	could	have	been	calculated	

and	bounded	as	it	should	have	been	under	OCAS-IG-003.	NIOSH	chose	the	easy	

road	and	used	generic, less	accurate	dosimetry	from	surrogate	sources	that	

were	not	justified	as	being	similar	to	GSI	medical	x-ray	diagnostic	equipment	

or	procedures.	

The	NRC	FOIA	2010-0012	documents	clearly	indicated	there	was	a	resident	inhouse	GSI	medical	staff	and	that	diagnostic	x-ray	examinations	were	

performed.	I	believe	that	NIOSH	routinely	evokes	ORAU-OTIB-0006	rather	

than	do	the	necessary	research	to	bound	a	site-specific	diagnostic	x-ray	dose.	

At	GSI,	there	was	specific	affidavit	testimony	from	GSI	worker	Dave	Woodard	

that	file	cabinets	with	employee	medical	records	were	spared	at	the	time	he	

was	charged	with	destroying	other	plant	records	after	casting	work	ceased	in	

1973	or	74.	The	files	were	taken	to	GSI	Corporate	headquarters	in	St.	Louis.	

There	is	no	indication	that	NIOSH	tried to	retrieve	GSI	medical	records.	

BB.4 Occupational External Dose 

Sources of external radiation exposure at GSI included betatron x-ray machines, sealed 

sources (Ra-226, Co-60, Ir-192), a 250 kvp portable x-ray machine and uranium metal. 

Except for the uranium, all these sources were used to x-ray metal. This process requires 

the operator to know the intensity of the radiation source at the metal, as well as the 

thickness of the metal in order to determine the length of time necessary to produce a 

clear x-ray image. Additional concomitant sources of radiation would interfere with the 

process and it is therefore assumed that workers are only exposed to one source of 

radiation at a time.

In estimating the external dose at GSI, the dose was estimated for a variety of exposure 

scenarios for the primary sources of external radiation. The limiting dose estimate for 

each scenario and job category will be used to estimate an individual’s external dose. For 

some scenarios, no numerical dose estimate was made because an analysis of the scenario 

compared to other numerical estimates was sufficient to eliminate it as a limiting 

scenario. This could be done by analyzing parameters that would be used in a 

numerical estimate for example determining less exposure time with all other parameters 

being equal.

[Page 7 of 38]

Doses will be assigned based on one of two job categories. The administrative category 

consists of people that spent most of their time in an office environment and did not 

routinely access the operating areas of the plant. The operator category consists of 

everyone that does not fit the administrative category. It is expected that the majority of 
DWM_GSIappBBr1_critique-F.doc

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workers will fall into this category. 

MCKEEL	COMMENT	to	BB.4	Occupational	External	Dose:	The	description	of	

these	various	non-Betatron	exposures	is	qualitative	and	inexact.	Thus,	I	do	not	

see	how	this	section	is	useful	at	all	to	dose	reconstructors.	Allen	evades	the	

actual	quantitative	calculation	and	bounding of	all	of	these	sources	with	

sufficient	accuracy.

The	phrase	“a	portable	250	Kvp	x-ray	machine”	is	inaccurate.	The	1974	GSA	

auction	of	GSI	equipment	showed	there	were	three	(3)	portable	250	Kvp	x-ray	

units,	two	industrial	and	one	for	medical	diagnosis	(such	as	chest	films).	

There	were	two	(2) Ra-226	sources.	NIOSH	does	not	know	when	leak	tests	

were	preformed,	when	these	units	were	purchased	or	how	long	they	had	been	

used,	or	what	was	the	actual	strength	between	1952	and	1962.	Of	course,	the	

strength	declined	over	the	course	of	these	10	years,	and	NIOSH	does	not	know	

the	start	point	or	who	the	vendor	was	for	these	sealed	source	isotopic	gamma	

NDT	sources.	

There	were	two	small	(0.5	Ci) Co-60	sources and	one	(1) large	80	curie	Co-60	

source at	GSI.	The	period	of	operation	for	the	large	Co-60	source	is	contested:	

6	workers provided	direct	eyewitness	affidavit	evidence,	which	Allen	and	

NIOSH	disregarded,	that	they	used	or	assisted	with	the	80	Curie	Co-60	source	

in	1964	through	1966, whereas	the	GSI	license	agreement	on	paper	says	the	

large	Co-60	80	Curie	source	was	not	authorized	by	the	AEC	until	1968.	We	do	

know	GSI	personnel	did	a	radiation	survey	of	the	New	Betatron	building	with	

the	large	80	Curie	Co-60	source	in	1971.	

The	St.	Louis	Testing	Company	Ir-192	source,	according	to	Paul	Sinn	2014	

testimony,	was	employed	at	GSI	at	least	25	to	50	times	that	he	knows	about.	

There	is	added	testimony	from	6	GSI	workers	that	GSI	owned	and	used	its	own	

Ir-192	source.	However,	there	is	no	written	or	testimonial	information	about	

how	frequently	the	GSI	Ir-192	source	was	used.	The	Ir-192	sources	were	used	

to	inspect	pipe	welds	as	one	documented	use	at	GSI.	A	1972	GSI	by-products	

material	license	documents	states	“this	facility	is	licensed for	iridium	and	

cobalt.” Allen-NIOSH	also	disregarded	this	fact	that	McKeel	put	on	the	record.

We	reject	the	type	of	reasoning	implicit	in	the	final	two	sentences	on	page	6	of	

38	beginning	with	“...For	some	scenarios,	no	numerical	dose	estimate	was	

made...”	Those	sentences	affirm	a	common	NIOSH	technique	that	avoids	

calculating	actual	delivered	doses,	that	is	identifying	“scenarios”	and	

“parameters”,	both	vague	qualitative	terms.	OCAS-IG-003	by	Dr.	Neton	

mandates	NIOSH	must	accurately	bound	all radiation	source	terms.

Summary:	NIOSH-Allen	failed	to	calculate	doses	for	any	of	these	sources	in	

AppBBr1	in	direct	violation	of	Neton/NIOSH	OCAS-IG-003	guidance.		
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10

BB.4.1 Betatrons 

[MCKEEL	PRELIMINARY	COMMENT	ON	SECTION	4.1]	-- Key	phrases	I	wish	to	

comment	upon	at	the	conclusion	of	section	BB4.1	Betatrons	are	bolded,	

assigned	a	number	and	are	enclosed	in	square	brackets	to	serve	as	reference	

points	for	the	concluding	comments.

[1. GSI had two betatron x-ray machines]. [2. The machines produced high energy 

x-rays (up to 25 MeV)] by accelerating electrons in a circular orbit then causing them to 

collide with a platinum target. The x-ray beam was measured by an ion chamber attached 

to the machine and the beam was “flattened” by an aluminum compensator designed to 

shield the high intensity center of the beam more than the lesser intense edges. This 

produced a usable area of relatively uniform intensity. 

While the head of the betatron can be moved throughout the shooting room, the betatron 

units were not mobile. They consisted of various components housed in a [3. specially 

designed shielded building]. The shooting room was surrounded by 10 foot thick walls 

consisting of 8 feet of sand sandwiched between 2 one foot thick concrete walls. [4. The 

“old betatron” was built in 1952] and [5. stood alone separated from other buildings 

on site]. [6. The “new betatron” was built in 1962] and was attached to building 10 by 

an equipment tunnel. [7. Figures 1 and 2 provide drawings] of the old and new betatron 

buildings, respectively. 

The intensity of the x-rays from the new betatron [8. was reported to be 250 R/min at 3 

feet from the platinum target with the aluminum compensator removed]. The 

compensator reportedly reduced the intensity by a third (Schuetz 2007). [9. The intensity 

of the old betatron was reported to be less.] However, [10. to avoid trying to place 

workers in one betatron versus the other], this appendix will use 250 R/min at 3 feet 

for all calculations. [11. Since the betatrons are not the limiting dose estimate prior to 

the construction of the new betatron, this is not an overestimate]. [12. Betatron xrays are of sufficient energy to produce nuclear interactions in material being xrayed causing some atoms to become radioactive]. That material then creates an [13. 

additional source of external radiation]. The external exposure scenarios explored for 

betatron operations include a scenario for the betatron operators and the layout man. The 

[14. layout man is a person assigned the duty] of marking the casting to determine 

what portions of the casting need to be x-rayed again, as well as marking any defects 

found in the previous shots. Several scenarios of workers working outside the betatron 

building were also evaluated, including working on the roof of the betatron building but 

[15. were found not be the limiting dose estimate due to limited exposure time or 

limited dose rates (DCAS GSI web page)]. 

This document will refer to the process of x-raying metal as shooting the metal or taking 

a shot. This is the vernacular used by former radiographers and avoids confusing an x-ray 

exposure with worker exposure to x-ray radiation. The betatron operator shooting 

scenarios consisted of a shooting scenario for uranium and a separate one for steel 
DWM_GSIappBBr1_critique-F.doc

11

castings. The scenario for the steel castings includes two different durations and 

distances, which were based on [16. interviews with former workers at GSI (SC&A 

2008)]. 

MCKEEL	COMMENT	ON	BB.4.1	Betatrons	(Part	1): My	comments	on	the	16	

foregoing	bracketed	passages	are	as	follows.	As	a	preface,	it	is	not	self-serving	

to	state	the	following	facts	that	support	the	assertion	that McKeel	and	

Ramspott,	the	GSI	SEC	co-petitioner	and	John	Ramspott,	the	chief	GSI	site	

expert	(refrerred	to	as	the	“GSI	expert	team”),	were	more	knowledgeable	

about	the	GSI	Old and	New	Betatrons	than	was	anyone	at	DCAS	NIOSH:	(a)	

DCAS	Director	Hinnefeld	at	a	GSI	worker	meeting	(p.	25,	8/21/06) stated	that	

Betatrons	were	not	particle	accelerators akin	to a	cyclotron.	This	is	factually	

untrue;	(b)	McKeel-Ramspott	(GSI	expert	team)	and	other	SINEW	steering	

committee	members	site	visited	the	GSI	Old	and	New	Betatron	facilities	in

September	2006 and	took	photos	and	videos	of	what	they	observed,	(c)	the	GSI	

expert	team	interviewed	Jack	Schuetz	at	length	in	Wisconsin	at	the	office	of	Dr.	

Vincent	Kuttemperoor,	who	subsequently	provided	testimony	to	the	

Radiation	Advisory	Board;	(d)	the	GSI	expert	team	site	visited	NDT	Specialties	

at	the	former	Allis-Chalmers	West	Allis,	WI	betatron	facility	in	2007	and	

viewed	one	of	the	few	remaining	in	use 24	Mev	betatrons	in	the	United	States;

[1.	GSI	had	two	betatron	x-ray	machines]	-- This	statement	of	fact	is	too	brief	

and	omits	the	facts	the	GSI	betatron	x-ray	units	were	electron	particle	

accelerators,	that	the	manufacturer was	Allis-Chalmers, and	the	two	GSI	

Betatron	serial	numbers,	which	were	provided	to	the	TBD-6000	WG	by	the GSI	

expert	team.	He	also	omits	the	fact	that	the	“new	Betatron”	was	built	by	AllisChalmers	in	1951	or	1952	and	was	installed	at	the	Eddystone,	PA	division	of	

GSI	and	used	for	ten	years.	The	unit	was	moved	to	GSI	in	Granite	City,	IL,	in	

1963	when	the	Eddystone	Division	in	PA	ceased	castings	operations;

[2.	The	machines	produced	high	energy	x-rays (up	to	25	MeV)]	-- Allen	omits	

the	key	fact	the	two	betatron	beams	at	GSI	also	produced	neutrons and	emitted	

electrons	by	stray	leakage.	Evidence	supporting	this statement	of	fact	is	the	

Schuetz	St.	Louis	hospital-based	betatron	unit	diagram	provided	to	DCAS	and	

Sam	Glover,	the	co-author	with	David	Allen	of	AppBBr0.	Jack	Schuetz	was	a	

paid	NIOSH	contractor and	betatron	service	person.	He	was	not	a	certified	

health physicist.	His	contract	terms have not	been	released	to	the	public.

[3.	...	specially	designed	shielded	building]	-- Allen	omits	the facts	that the	

design	parameters	and	construction	techniques	differed	between	the	Old	and	

New	Betatron	buildings	at	GSI	Granite	City,	IL.	The	Chicago	District,	US	Army	

Corps	of	Engineers, built	the	Old	Betatron	facility	owned	by	the	US	government	in	1951.	The	Old	Betatron	unit	was	placed	into	operation	in	January	

1952,	according	to	several	local	newspaper	stories	the	GSI	expert	team	

provided	to	Allen	and	the	TBD-6000	WG.	GSI	built	the	New	Betatron	facility	in	

1963.	No	blueprints	exist	of	either	GSI	Betatron	building.	
DWM_GSIappBBr1_critique-F.doc

12

[4.	The	“old	betatron”	was	built	in	1952]	-- As	outlined	above,	NO,	the	Old	

Betatron	building was	constructed	during	1951 not	1952.	Betatron	operations

for	steel	and	MCW	uranium	R&D	commenced	in	January	1952 at	IL	GSI.

[5.	(OBB)	...	stood	alone	separated	from	other	buildings	on	site]	-- Allen	omits	

several	facts.	The	GSI	Old	and	New	Betatron	buildings	were	separated	from	

one	another	by	only	300	feet.	Also,	signs	on	the	Old	Betatron	building	

indicated	“Do	Not	Approach	This	Building	within	100	Feet.” McKeel	

photographed	these	signs	in	September	2006. Furthermore, it is known that 

unobstructed neutrons may travel 3000 feet in air. The GSI expert team therefore 

believes that workers at both Betatron facilities, which could both be operating at 

the same time during 1963-1973, could be cross-irradiated by photons and neutrons 

emanting from the other Betatron facility (both units ON at the same time). 

[6.	The	“new	betatron”	was	built	in	1962]	-- It	is	not	clear	whether	“new	

betatron”		refers	to	the	A-C	Betatron	particle	accelerator unit	itself	or	to	the	

building that	housed	it.	The	New	Betatron	unit	was	built	by	A-C	in 1951	or	

1952.	The	New	Betatron	building at	1417	State	Street,	Granite	City,	IL	may	

have	been	constructed	by	GSI	as	early	as	1962.	These points	need to	be	

clarified	in	the	AppBBr1	text.

[7.	Figures	1	and	2	provide	drawings]	-- Actually,	Figures	1	through	5 inclusive	

provide	GSI	Old	and	New	Betatron	building	drawings.	Allen	omits	the	source	

documents	for	these	cartoon	sketches.	They	were	not	drawn	based	on	any	

extant	blueprints.	To	the	knowledge	of	the	GSI	expert	team,	NIOSH	made	no	

effort	to	obtain	Old	Betatron	building	blueprints	or	purchase	orders	or	

construction	permits	or,	in	fact,	any	records	about	the	Old	Betatron	Building	

and	installation	from	USACE.	The	agency	should	have	made	this	effort;	that	is	

part	of	their	job.	The	quality	of	reproduction	of	these	figures	is	poor	and	

better	drawing	copies	should	be	substituted.	Some	of	the	lines	and	labels	are	

indistinct.	In	all	cases,	exact	citations	should	be	given	as	to	the	reference	

source	documents	for	each	of	the	Old	and	New	Betatron	building	drawings	

used in	AppBBr1,	which	is,	after	all,	a	scientific	technical	document. The	

various	Betatron	building	sketches	were	done	at	different	time	points	and	

they	vary	in	significant	ways	that	need	to	be	pointed	out	explicitly	(as	has	

been	done	by	the	SINEW	expert	team)	by	Mr.	Allen	and	DCAS/NIOSH.

[8.	was	reported	to	be	250	R/min	at	3	feet	from	the	platinum	target	with	the	

aluminum	compensator	removed] -- Allen	omits	the	source	of	this	key	

information	which	should	be	included	(and	referenced)	in	this	report.

[9.	The	intensity	of	the	old	betatron	was	reported	to	be	less.]	-- What	is	the	

source	document	reference	that	validates	this	statement?	The	phrase	“...	to	be	

less” is	merely	qualitative.	Quantitative	data is	required	in	a	dose	

reconstruction	guidance	whose	audience	is	professional	health	physicists.	

Jack	Schuetz	provided	some	GSI	donut	tube	output	data	that	indicated	the	Old	
DWM_GSIappBBr1_critique-F.doc

13

Betatron	output	was	closer	to	100	R/minute.	It	is	good	to	be	exact	rather	than	

vague	and	indefinite	in	scientific	writing as	a	scientific	“best	practice.”

[10.	...	to	avoid	trying	to	place	workers	in	one	betatron	versus	the	other]	-- The	

reason	Allen	has	to	resort	to	this	ploy	is	that	NIOSH	or	DOL	cannot	possibly	

place	individual	radiographers	relaiably	at	the	Old	and	New	Betatrons.	There	

is	conflicting	information	about	which	Betatrons	were	used	how	often	for	

MCW	(AEC)	uranium	contract	work.	No	related	shot	records,	shipping	

manifests,	or	uranium	work	lists	apparently	exist	at	either	GSI	or	MCW	

current	records	repositories. Again,	the	Betatrons and	the	Betatron	buildings	

at	GSI	differed	structurally,	mechanically and	electronically.	OCAS-IG-003	

mandates	that	external	x-ray	photons,	neutrons	and	beta	be	determined	

(“bounded”)	for	each	facility	to	allow	a	valid	quantitative	comparison	to	be	

made.

[11.	Since	the	betatrons	are	not	the	limiting	dose	estimate	prior	to	the	

construction	of	the	new	betatron,	this	is	not	an	overestimate]	-- Once	again,	Mr.	

Allen	leaves	key	information	to	the	imagination by	using	this	double	negative	

statement.	If	the	betatrons	are	not	(dose	limiting),	what	is dose	limiting?	I	

assume	Allen	is	referring	to	the	radium-226	sources.	The	doses	NIOSH	assigns	

to	the	Old	and	New	Betatrons	and	two radium-226	sources	at	GSI	need to	be	

stated.	It	needs	to	be	reiterated	that	the	2008	Betatron	operator	doses	

assigned	by	both	NIOSH	and	SC&A	were	vastly	(~10-fold)	higher	than	than	

doses	they	are	using	in	AppBBr1	apparently,	which	are	based	on	2012	

modeling	based	in	part	on	Landauer	Program	#2084	film	badge	monitoring	

data	on	GSI	radiographers.	Since	NIOSH	declared	it	would	abandon	use	

of	the	GSI	Landauer	FB	data	in	2014	based	on	the	Hinnefeld-Yoder	

interactions	reported	by	Neton,	the	2012	lower	,	film-badge	normalized	

Betatron	external	doses	compared	to	2008	values	are	no	longer	valid	in	my

opinion.	The	2012	GSI	Betatron	radiographer	dosimetry	data	should	be	

retracted and	recalculated omitting	any	reference	to,	or	use	of,	Landauer	FB	

data.	AppBBr1	(June	6,	2014)	errs	in	being replete	with	references	to	and	use	

of	GSI	Landauer	FB	data. It	is	as	though	the	Neton	memo	of	the	HinnefeldYoder	decision	for	NIOSH	to	not	use Landauer	FB	data	at	GSI	never	existed.	

The	hard	and	inconvenient	fact	is	this	memo	does	exist.	See	the	excerpt	below:

[Begin	quote] Dear Josh (from Dan McKeel to Kinman 12.19.2013),

Could you please provide me with the Jim Neton original e-mail itself so I can 

learn when the message was transmitted to the work group including the Board 

members and SC&A. That action was completed in time for Bob Anigstein to 

incorporate the Neton message into the revised Appendix BB issues SC&A 

matrix everyone on the WG, including me, apparently received yesterday, the 

day it was dated is Dec. 18, 2013. Thank you.
DWM_GSIappBBr1_critique-F.doc

14

Sincerely -- Dan McKeel 12.19.13

Daniel McKeel

Phone: 573-323-8897

Fax: 573-323-0043

Email:danmckeel2@aol.com

P.O. Box 15, Van Buren, MO 63965 [end quote]

[Note:	The	original	Neton	e-mail	was	not provided	to	McKeel]

December	19,	2013

To	members	of	the	TBD	6000	working	group	and	other	interested	parties:

During	the	October	11	working	group	discussion	of	open	items	on	SC&A’s	

review	of	the	GSI	site	profile,	NIOSH	raised	an	issue	concerning	the	correct	

interpretation	of	Landauer	control	film	badge	readings. Based	on	an	

interview	with	a	former	Landauer	official,	who	is	now	a	member	of	the	

SC&A	staff,	SC&A’s	position	is	that	measured	exposure	on	control	badges	

were	reported	to	the	customer	as	“M”,	if	the	control	film	read	less	than	50	

mrem	and	was	lower	than	half	of	the	badges	issued	to	workers. As	has	

been	discussed,	Landauer’s	practice	is	to	report	film	badges	with	exposures	

less	than	the	detection	limit	as	“M”. Because	SC&A’s	write	up	on	this	issue	

left	some	room	for	interpretation,	NIOSH	proposed	that	we	contact	

Landauer	to	verify	that	this	was	actually	the	practice.	 It	was	important	to	

verify	this	point,	because	NIOSH’s	approach	to	bounding	a	

worker’s	 betatron	exposure	relies	on	the	fact	that	the	control	badges	

never	received	a	detectable	exposure. After	some	discussion,	it	was	

decided	that	Stu	Hinnefeld,	the	director	of	DCAS,	would	contact	Landauer	

for	clarification.

Shortly	after	the working	group	meeting,	Mr.	Hinnefeld	sent	an	e-mail	to	

Craig	Yoder,	a	Senior	Vice-President	at	Landauer. Dr.	Yoder	has	been	with	

Landauer	for	30	years	and	possesses	an	in	depth	knowledge	of	the	

company’s	current	and	past	dosimeter	processing	practices. Through	a	
DWM_GSIappBBr1_critique-F.doc

15

follow-up	phone	conversation	and	subsequent	e-mail	exchange,	it	was	

learned	that	SC&A’s	characterization	of	the	reporting	of	control	badges	was	

accurate. The	following	bullets	summarize	the	salient	points	of	the	

conversation	between	Mr.	Hinnefeld	and	Dr.	Yoder:

· Pieces	of	film	were	kept	at	Landauer	from	each	batch	of	film	to	

be	used	as	internal	controls.

· When	a	set	of	customer	films	were	returned,	internal	controls	

from	that	batch	of	film	were	included	in	the	development	and	

reading	process.

· Optical	Density	(OD)	from	internal	controls	is	subtracted	from	

the	OD	of	all	customer	badges.

· During	the	1960s, ODs	of	customer	badges	are	converted	to	units	

of	dose.

· The	customer	control	result	in	mR	is	subtracted	from	all	

customer	badges,	including	customer	control. Customer	control	is	

reported	as	M.

· For	example,	if	a	customer	control	read	30 mR	after	subtraction	

of	internal	control,	it	would	it	be	reported	as	M.

· If	the	customer	control	read	50	mR	or	higher,	the	customer	

would	be	told	what	it	read	and	what	value	had	been	subtracted	

from	all	customer	badges,	but	the	customer	control	would	still	be	

reported	as	M.

Based	on	Landauer’s	practice	of	subtracting	the	control	badge	result	from	

itself,	the	NIOSH	proposed	method	for	bounding	exposures	to	betatron	

workers	at	GSI	cannot	be	used. Thus,	NIOSH	proposes	to	adopt	the	limiting	

value	for	exposure	to	betatron	operators	proposed	by	SC&A,	which	does	

not	rely	on	the	use	of	film	badge	data.

Jim		[Neton,	last	name/underlining	added	by	Dan	McKeel	7.13.14]

[12.	Betatron	x-rays	are	of	sufficient	energy	to	produce	nuclear	interactions	in	

material	being	x-rayed	causing	some	atoms	to	become	radioactive]	-- The	

process	being	described	is	that	of	ACTIVATION	and	it	should	be	labeled	as	

such.	Actually,	studies	have	shown	that	almost	all	known	elements	can	be	

radiation-activated.	This	is	the	basis	for	the	subsciences	of	photon	and	

neutron	activation	elemental	analysis	widely	used	in	academia,	industry	and	
DWM_GSIappBBr1_critique-F.doc

16

medicine.	This	branch	of	analytic	chemistry	applied	physics	is	robust	and	

mature	and	is	supported	by	a	vast	scientific	literature.

•	What	Mr.	Allen	unfortunately	omits	in	this	statement	is	that	in	the	case	of

MCW	uranium-238,	24-25	Mev	betatrons	are	energetic	enough	(the	threshold	

is	around	6	Mev)	to	cause	fission,	producing	two	daughter	radioisotopes	(the	

Sugarman	references	the	GSI	expert	team	provided	to	NIOSH	and	the	TBD6000	WG	and	Board	in	2006)	as	well	as	activation.	Allen omits	the	key	

information	that	many	activation	products	produced	as	a	result	of	Betatron	

bombardment	of	steel	and	uranium	have	half	-lives	that	are	much	longer	than	

the	2	hours	NIOSH	restrictively	allots	in	a	claimant	unfavorable	way.	The	GSI	

expert	team	believes	the	activation	contribution	to	external	dose	caused	by	

the	Betatron	x-irradiation	of	high	nickel	content	steel,	including	the	x-ray	

cassettes	used	in	Betatron	x-ray	NDT	radiography, and	uranium	is	

significantly	underestimated	by	NIOSH. In	fact.	The	chief	GSI	site	expert		

persuaded	St.	Louis	Testing	Company	to	quantitatively	analyze	whether the	

GSI	Betatron	team	x-ray	film	cassettes	indeed	had	a	high	nickel	content. The	

data	answered	this	question “YES”	in	a	positive	manner.

[13.	([that	material	then	creates]	an	additional	source	of	external	radiation]	--

This	passage	is	referring	to	activation	products	as	“that	material.”	As	stated	in	

item	12,	McKeel, in	his	3/15/12	TBD-6000	WG	meeting	PowerpointTM

presentation,	and	in	the	GSI	SEC-00105	AR	and	several	McKeel	white	papers,	

showed	data	proving	that	activation	products	caused	by	linear	(Ziemer	and	

Guo	2004)	or	circular	particle	accelerators	(Kuttemperoor	1974)	produce	

radioisotopes	with	half-lives	longer	than	2	hours,	the	claimant	adverse	cutoff	

for	Betatron	activation-product	external	exposure	embraced	by	NIOSH.

[14.	layout	man	is	a	person	assigned	the	duty...]	-- The	layout	man	concept,	as	

promoted	by	SC&A	and	adopted	by	NIOSH	and	the	TBD-6000	WG,	is	deeply	

flawed	and	impossible	to	implement,	as	stated	elsewhere	in	this	critique	of	GSI	

AppBBr1.	There	is	no	exclusive	union	job	category	of	Layout	man	at	GSI,	a	

strong	union	shop.	Radiographers	did	Betatron	and	isotope	and	often	

Magnaflux	NDT	work.	Layout	man	is	not	at	all	representative	of	many	of	the	

163	job	categories	we	know	existed	at	GSI.	Most	of	these	workers	had	nothing	

to	do	with	Betatron	operations	except,	and	importantly,	welders,	chippers,

grinders	and	burners	were	exposed	to	activation	products of	steel	that	NIOSH	

underestimated	in	a	claimant	unfavorable	way.	Finally,	DOL	will	not	be	able	to	

identify	Layout	Man	claimants	from	their	database.	Rachel	Leiton,	DEEOIC	

Director	at	DOL, explained	to Dan	McKeel	that	the DEEOIC/DOL computer	

system was	not	capable	of identifying GSI	radiographers,	many	of	whom	were	

listed	as	“chemical	operators.”	The	Layout	Man	concept	is	an	impossible	to	

implement	non-categorical,	jargon	term	that	does	not	represent	all	3000	to	

5000	(estimates	veried)	workers	other	than	radiographers	at	the	GSI	plant.

[15.	were	found	not	be	the	limiting	dose	estimate	due	to	limited	exposure	time	

or	limited	dose	rates	(DCAS	GSI	web	page)]	-- Again,	Allen	should	provide	the	
DWM_GSIappBBr1_critique-F.doc

17

actual	measured	exposure	values	in	mRem	or	other	units	to	validate	this	

qualitative	statement.	GSI	made	single	measurements	at	the	GSI	New	Betatron	

building	using	an	atypical	80	Curie	Co-60	source	(not	a	24-25	Mev	Betatron	

which	may	have	caused	higher	values	of	exposure)	in	1971,	outside	of	the	

operational	period	at	GSI	which	ended	in	June	1966.	The	GSI	expert	team	has	

contended	all	along	the	Co-60	source	data is	not	a	suitable	surrogate	for	two

24-25	Mev	Betatron electron	particle	accelerators	operating	with	platinum	

targets	in	x-ray	mode.	The	Co-60	source	is	omni	directional (radiates	in	360	

degrees),	whereas	the	Betatron	beam	is	sharply	focused	in	one	direction.	The	

Co-60	sources produce	gamma	photons	but	essentially	no	neutrons	in contrast	

to	the	Allis-Chalmers 24-25	Mev	twin	Betatrons	at	GSI	which	produced	x-rays	

and	neutrons	and	stray	(column	leakage)	electrons. There	was	residual	

column	and	component	activation	radiation	from	the	Betatron	sources	after

the	power	was	turned	OFF,	in	contrast	to	the	Co-60	sources	where	there	was	

no	residual	gamma	radiation	once	the	sources	were	replaced	in	their	lead	

shilded	“pigs.” The	SINEW	teams	contends	the	Betatron	components	were	

chronically	activated	as	the	source	of	the	“OFF”	power	source	radiation.

[16.	interviews	with	former	workers	at	GSI	(SC&A	2008)]	-- The	date	of	the	

SC&A	Collinsville,	IL	GSI	worker	satellite	meeting	was	October	9,	2007 not	

2008.	NIOSH	needs	to	change	the	date	error.

[Page 8 of 38]

[1. The uranium shots took 60 minutes for the actual shot as well as 15 minutes between 

shots to allow for setting up the next shot]. The shots were taken at a distance of six feet 

from the betatron target to the material. This scenario would allow for an average of 6.4 shots 

per 8 hours shift of continuous uranium operations. It also results in the betatron being 

energized 80% of the time while uranium is being x-rayed. [2. The steel casting scenario 

consists of two types of shots.] The first type (short shot) is 3 minutes in duration with 12 

minutes between shots. These shots are taken at a distance of nine feet between the betatron 

target and the material. With one short every 15 minutes (3 minute shot plus 12 minutes 

between), an average of 32 shots can be taken during an 8 hour shift. The second type of shot 

was the long shot. Just like the uranium shots, these shots were taken at six feet and lasted 60 

minutes with 15 minutes between. [3. Long shots were assumed to account for 10% of the 

steel casting shots while short shots accounted for the other 90%]. This combined with 

the shot scenarios results in an average of 20.57 short shots and 2.29 long shots per 8 hours 

shift. It also results in the betatron being energized 41.43% of the time while x-raying steel. 

Figure 1 – Drawing of the Old Betatron Building

Drawing of the old betatron building from FUSRAP documentation

(See	following	page)
DWM_GSIappBBr1_critique-F.doc

18

MCKEEL	COMMENT	on	Figure	1.	This	drawing	above	appears	to	be	an	MCNP	

construct	rather	than	a	FUSRAP drawing.	Allen	needs	to	provide more	exact	

reference	to	a	specific	FUSRAP	report	title,	number	and	page to	refute	this	

interpretation.

[Page 9 of 38]
DWM_GSIappBBr1_critique-F.doc

19

Drawing of the new betatron building from FUSRAP documentation

As previously stated, the layout man is a person assigned the duty of marking the casting 

to determine what portions of the casting need to be x-rayed again, as well as marking 

any defects found in the previous shots. [4. This is a limiting exposure scenario 

because the layout man can be working in close proximity to freshly x-rayed 

castings. While the layout man is a duty performed by radiographers, other classes 

of employees can also be working in close proximity to these freshly x-rayed 

castings]. This is due to the fact that defects found during radiography are often repaired 

(for example, grinding out the defect and adding good metal back in by welding). Also, 

betatron operators were radiographers but others were also associated with the betatron 

operators and could receive the same type of exposure. For example, riggers may be used 

to move the castings in and out of the betatron building as soon as the x-ray is done. [5. 

Therefore, the dose estimate for betatron operators and for the layout man is 

applied to essentially everyone working at the site]. [6. The exception is 

administrative personnel]. 

Betatron operators are modeled as being in the betatron control room during the shots and 

near the freshly x-rayed material between the shots starting 5 second after the end of the 

x-ray to allow travel time to the material. 

During x-rays, the layout man is assumed to be in the #10 building near the railroad 

tracks used to move castings into and out of the new betatron building. [7. The layout 

man is not assumed to be in the middle of the doorway since that would not be a 

credible location for a casting. That would block the path to and from the betatron 

building.] Instead, he is assumed to be 10 feet to the side of the railroad tracks. Both 
DWM_GSIappBBr1_critique-F.doc

20

sides were modeled and the higher dose rate side was used in the estimate. [8. This 

scenario for the layout man would only be applicable after 1962 when the new 

betatron was built. A similar location for the old betatron would be outdoors and it 

is unlikely this work routinely occurred there year around]. It is much more likely the 

work was done in another building then the casting transported to the old betatron 

building. This would result in a considerably lower dose to the layout man before 1963. 

[9. However, Ra-

[Page 10 of 38]

226 radiography resulted in an exposure estimate higher than the new betatron layout 

man estimate so the lower exposure scenario was not explored further].

MCKEEL	CONCLUDING	COMMENT	to	BB.4.1.	Betatrons	(part	2 pages	8-10):	

(passages	marked	off	with	numbers,	square	brackets	and	bolded):

[1.	The	uranium	shots	took	60	minutes	for	the	actual	shot	as	well	as	15	minutes	

between	shots	to	allow	for	setting	up	the	next	shot]	-- These	time	intervals	are	

from	but	a	sigle	radiographer	out	of	three	who	gave	specific	testimony	about	

GSI	uranium	Betatron	shots.	The	GSI	expert	team,	especially	the	main	chief	

site	expert,	challenged	these	numbers.	Again,	David	Allen	and	the	TBD-6000	

chose	to	disregard	this	added/alternate testimony	which	provided	more	shots	

and	shorter	intervals	between	shots.	The	selected	testimony	is	NOT	the	most	

claimant	favorable.

•	The	comment	should	be	made	that	Betatron	shots	records	were	never	

located.	Worker testimony	about	shot	times	varies.	It	is	difficult	to	understand	

how	NIOSH	seemingly	arbitrarily	accepts	certain	worker	testimony	(one	of	

three	versions	of	the	uranium	shot	time	intervals)	and	rejects	other	testimony	

(about	the	GSI	Ir-192	source	and	the	large	Co-60	source	1064-66),	for	

example.

•	I	sense	that	Mr.	Allen’s	mind	was	set	long	ago	on	the	“facts”	as	he	chose	to	

view	them,	and	that	subsequent	testimony	was	disregarded	as	the	default	

position	of	DCAS/NIOSH.	This	is	not	acceptable	porfessional	scientific	

behavior.

[2.	The	steel	casting	scenario	consists	of	two	types	of	shots.] -- This	narrative	

leaves	out	completely	the	facts	that	all	GSI	Betatron	and	isotopic	shot	records	

and	log	books	were	destroyed	or	lost.	No worker	was	in	a	position	to	accurately	

know	the	“big	picture”	of	what	the	ratio	was	of	short	and	long	steel	shots.	The	

definitions	used	by	Allen	in	AppBBr1	may	be	challanged	as	well.	Where	is	the	

exact	quote	recorded	that	supports	his	version	of	reality?	This	key	testimony	

should	be	cited,	the	affidavit	number	and	place	and	date	of	the	worker	meeting	

identified,	and	the	full	citation	should	then	be	included	in	the	References.

[3.	Long	shots	were	assumed	to	account	for	10%	of	the	steel	casting	shots	while	

short shots	accounted	for	the	other	90%]	-- Refer	to	issue	2.	Some	steel	castings	
DWM_GSIappBBr1_critique-F.doc

21

imaged	by	GSI	were	huge	and	required	dozens	of	separate	exposures	that	

required	days	to	complete.	There	is	no	way	of	knowing	with	any	degree	of	

accuracy	the	ratio	of	short	and	long	shots.	Even	the	concept	is	simplistic	as	I	

am	sure	real	GSI	shot records	would	prove	and	confirm. NIOSH	could	have	

obtained	shot	records	from	the	operating	A-C	Betatron	the	GSI	expert	team	

observed	being	operated	in	West	Allis,	WI	(NDT	Specialties).	NIOSH	and	the	

TBD-6000	WG	was	informed	about	this	real	world	current	Betatron	resource.	

NIOSH	and	SCA	again	chose	to	ignore	the	information	provided	to	them	in	

good	faith by	the	SINEW	site	expert	team.

[4.	This	is	a	limiting	exposure	scenario	because	the	layout	man	can	be	working	

in	close	proximity	to	freshly	x-rayed	castings.	While	the	layout	man	is	a	duty	

performed	by	radiographers,	other	classes	of	employees	can	also	be	working	in	

close	proximity	to	these	freshly	x-rayed	castings]	-- Direct	eye	witness	

testimony	indicates	layout	men	and	plant	welders,	grinders,	chippers	and	

burners	worked	with	freshly	x-irradiated	Betatron	inspected	steel	castings.	

Sometimes	this	work	was	performed	on	a	RR	transfer	car	waiting	on	the	

tracks	within	the	tunnel	that	house	railroad	tracks	inside	the	building	

perimeter	but	located	in	a	tunnel	that	extended	into	the	Betatron	shooting	

rooms	(see	item	7).	However,	many	non-radiographer	GSI	workers	did	not	

come	into	contact	with	Betatron	x-ray’d steel	and	worked	in	buildings	far	

away	from	building	10	which	adjoined	the	New	Betatron	facility. Layout	man	

does	not	apply	to	them,	so	how	will	such	workers	be	handled	by	DR	

personnel?

[5.	Therefore,	the	dose	estimate	for	betatron	operators	and	for	the	layout	man	is	

applied	to	essentially	everyone	working	at	the	site]	-- The	entire	paragraph	that	

contains	this	passage	is	very	confusing.	If	everyone	at	the	GSI	plant	will	be	

assigned	the	same	external	photon dose,	does	this	also	apply	to	neutrons?	Why	

not	just	make	a	single	class	of	GSI	workers	and	give	them	the	highest	value	of	

the	triangluar	photon	distribution? I	doubt	that	dose	reconstructor	health	

physicists	will	fully	understand	the	rationale	for	this	confusing	guidance.	

[6.	The	exception	is	administrative	personnel]	-- Dr.	Ziemer	first	suggested	

making	this	a	separate	category	of	GSI	personnel	for	dose	reconstruction	

purposes.	No	such	designation	was	included	in	AppBBr0.	Allen	should	have	

stated	that	fact,	and	why	an	administrative	personnel	category	was	necessary

in	the	2014	revised	version	of AppBB.	There	is	abundant	testimony	at	GSI	that	

the	job	category	“secretary” included	personnel	who	never	visited	the	

production	area	(very	rare)	and	many	persons	who	needed	to	go	into	the	rest	

of	the	plant	on	a	regular	basis. One	major	problem	is	the	CATI	interview	is	not	

designed	to	reliably	distinguish	between	these	two	types	of	individuals.	I	

predict	that	errors	will	be	on	the	side	of	reducing	doses	to	persons	the	

individual	dose	reconstructor	believes	never	visited	the	plant.	The	

information	in	most	cases	to	decide	this	question	will	be	lacking	in	most cases.	

An	overall	criticism	of	AppBBr1	is	that	by	June	2014,	NIOSH	should	be	able	to	
DWM_GSIappBBr1_critique-F.doc

22

certify	how	many	individuals	among	those	with	already	completed	dose	

reconstructions	could	be	classified	as	administrative	personnel. That	

information	has	not	been	forthcoming	to	my	knowledge.

[7.	The	layout	man	is	not	assumed	to	be	in	the	middle	of	the	doorway	since	that	

would	not	be	a	credible	location	for	a	casting.	That	would	block	the	path	to	and	

from	the	betatron	building.]	-- According	to	worker	testimony,	some	layout	

work	was	indeed	done	on	castings	that	were	just	outside	the	shooting	room	

door	inside	the	tunnels	of	both	Old	and	New	Betatrons	(see	also	item	8).	It	was	

possible	to	fit	two	electric	transfer	cars	in	the	New	Betatron	building	interior	

(one	in	the	shooting	room	and	one	outside	the	ribbon	door).	The	shooting	

room	steel	door	could	be	closed	between	the	first	and	second	transfer	cars	

and	betatron	shots	could	be	made	on	either	car	en	place.

[8.	This	scenario	for	the	layout	man	would	only	be	applicable	after	1962	when	

the	new	betatron	was	built.	A	similar	location	for	the	old	betatron	would	be	

outdoors	and	it	is	unlikely	this	work	routinely	occurred	there	year	around]	--

Again	the	second	sentence	should be	amended	to	read	“...	when	the	new	

betatron	building was	built.”	GSI	radiography	supervisor	Ed	Holshouser	

testified	in	2014	that	he	observed	trucks	bringing	groups	of	8	to	12	MCW	

uranium	ingots on	wood	palettes	to	the	Old	Betatron	tunnel	doorway.

[9.	However,	Ra-226	radiography	resulted	in	an	exposure	estimate	higher	than	

the	new	betatron	layout	man	estimate	so	the	lower	exposure	scenario	was	not	

explored	further]	-- This statement	needs	to	be	supported	in	the	text	by	a	Table	

or	an	explicit	listing	of	the	gamma	photon	doses	assigned	to	the	New	Betatron	

layout	person	and	to	a	Ra-226	radiographer	who,	again,	might	be	the	same	

individual	at	different	times.	However,	the	external	neutron	dose	would	be	

higher	for	the	New	Betatron	(and	Old	Betatron)	layout	men because	Ra-226	is	

primarily	a	gamma	photon	source	and	gives	off	neutron	doses	that	are	usually	

considered	negligible.	Allen	ignores	the	facts	in	his	tables	that	GSI	1952-1962	

radiographers	operated	both	Ra-226	and	Betatron	NDT	sources.	The	photon	

doses	for	layout	man	as	calculated	in	2012	(but	not	in	2008)	were	highest	

when	using	Ra-226	sources	because	these	sources	could	only	be	bounded	

according	to	then	current	AEC	radiation	safety	limits.	The	neutron	doses	were	

significant;y	higher for	Betatron	NDT	operators	compared	to	Ra-226	isotope	

NDT	source	operators. Allen	needs	to	incorporate	these	neutron	dose	facts.

BB.4.2 Betatron Building Model 

Documents obtained from AEC license applications contained building dimensions and other 

details for the new betatron building (Figures 3 through 5). The documents also included a 

survey of the new betatron building with an 80 curie cobalt-60 source exposed that was 

conducted on January 29, 1971. The survey, which included measurements taken at various 

points around the building, is reproduced in Table 3. The letters in parentheses correspond to 

the locations identified in Figures 3 through 5. 
DWM_GSIappBBr1_critique-F.doc

23

The building design information contained in the AEC license application was used to 

modify a previously constructed MCNP model of the new betatron building. MCNP is a 

general purpose Monte Carlo radiation transport computer code designed to track many 

particle types over a broad range of energies. It was developed at Los Alamos National 

Laboratory with new versions released periodically. MCNP calculations for this document 

were performed using MCNPX versions 2.6 and 2.7 as well as MCNP6. This document will 

refer them generically as MCNP. 

Once the model of the new betatron building was modified, an 80 curie Co-60 source was 

added at the position labeled as an X within a circle in Figure 3. Radiation levels were 

determined, using MCNP, at many of the same locations surveyed by GSI in 1971. Table 3 

provides a comparison between the actual survey results and the modeled results.

MCKEEL	COMMENT	to	BB.4.2	Betatron	Building	Model:

•	FIRST	PARAGRAPH:	Mr.	Allen	should	provide	“ML”	document	numbers	and	

specific	page	citations	for	the	AEC	license	documents	he	refers	to.

•	SECOND	PARAGRAPH:	The	information	about	MCNPX	software	is	very	

incomplete	and	sketchy	and	thus	is	necessarily	misleading.	A	major	problem	

is	that	photon,	neutron	and	beta	doses	varied	depending	on	which	specific	

software	version	of	MCNP	was	used.	That	is,	the	doses	changed	over	time.	Left	

out	by	Allen	is	the	fact	that	MCNPX	NIOSH	and	SC&A	dosimetry	values	always	

varied	significantly and	by	a	different	amount	in	2008	and	2012.	

•	Allen	should	have	admitted	that	neither	DCAS	nor	SC&A	had	any	measured	

A-C	24-25	Mev	Betatron	photon,	neutron	or	beta	data	to	compare	with,	or	to	

validate	their	MCNPX	results.	The	GSI	expert	team	stated	many	times	on	the	

record	that	peer	reviewed	scientific	journals	always	require	validating	

measured	data	which	agrees	with	the	modeled	data	by	±	10	to	20%	maximum.	

Neither	the	2008	nor	the	2012	NIOSH	or	SC&A	MCNPX	modeled	data	values	

met	that	crucial	test.	NIOSH	(Allen)	should	reiterate	here	why	they	rejected	

use	of	NYO-4699(Suppl.	1)	HASL/AEC	generated	22	Mev	Betatron	photon	and	

neutron	and	film	badge	measured	data	from	three	surrogate	sites.

•	Allen	should	have	compared	Betatron	radiographer	and	other	plant	worker	

doses	modeled	with	MCNPX	versions	by	both	SC&A	and	NIOSH	in	AppBBRev0

(June	2007),	in	2008	and	in	2012	in	AppBBr1.	The	differences	are	large	and	it	

is	up	to	Allen	and	NIOSH	to	justify	using	this	highly	discrepant	data	for	future	

dose	reconstructions	including	reopened	“rework”	GSI	DRs	that	will	result	

from	the	new	PER	issued	as	a	result	of	revising	TBD-6000	Rev	0	(in	June	

20011)	and	Appendix	BB	Rev	0	(in	June	2014).

•		THIRD	PARAGRAPH:	The	analysis	in	the	final	paragraph	of	this	section	

shows	“reasonable	agreement”	between	measured	and	MCNPX	modeled	

photon	data	using	a	cobalt-600	omnidirectional	gamma	photon	source	that	

emits	essentially	no	neutrons.	The	GSI	80	Curie	Co-60	source	according to	

documents	in	NRC	FOIA	2010-0012	was	not	licensed	until	1968,	and	NIOSH	
DWM_GSIappBBr1_critique-F.doc

24

thus	did	not	assign	doses	to	personnel	from	that	source	during	the	residual	

period. SINEW	believes	worker	testimony	should	be	accepted,	and	the	80	Ci	

Co-60	GSI	source	bounded	for	the	years	1964-June	1966.

[Page 11 of 38]

MCKEEL	COMMENT	ON	FIGURE	3	-- A clearer	copy	of	this	drawing	needs	to	be	

substituted.	The	lines	and	text	are	faded	and are	difficult/impossible	to	read.	

The	quality	is	unacceptable	for	an	important	scientific	publication.
DWM_GSIappBBr1_critique-F.doc

25

[Page 12 of 38]

MCKEEL	COMMENT	ON	FIGURES 4 and	5	-- Clearer	copies of	these drawings	

need to	be	substituted.	The	lines	and	text	are	faded,	text	is	difficult or	

impossible	to	read.	The	quality	is	unacceptable	for	a scientific	publication.
DWM_GSIappBBr1_critique-F.doc

26

[Page 13 of 38]

The modeled values were found to be either higher or within 20% of the measured values. 

One point located 10 feet from the double leaf door, 12 feet high showed a significant 

difference. Inspection of the other survey results near that door revealed that all other 

measured results, 10 feet or more above the floor, are at least 1.8 mR/hr. The survey 

measurement at that point, however, is 0.2 mR/hr. The difference between the model and the 

measured results could be a typographical error or an error in reading the instrument (such as 

the wrong scale). Since the scales on instruments are typically factors of 10, it is very 

possible the actual reading was 2.0 mR/hr. The other possibility is that there could be some 

piece of equipment mounted there (such as a door motor) creating additional shielding that is 

not depicted in the model. Either way, the values 5 feet above the floor are more 

representative of the location of workers and those values differ by no more than 0.2 mR/hr. 

The reasonable agreement between the modeled and measured exposure values indicates that 

the building model provides a realistic representation of the shielding presented by the new 

betatron building. This model was used later to estimate dose rates from various shooting 

scenarios in the new betatron building with one notable exception. The survey description in 

the AEC license application indicates the double leaf door contained lead in the bottom 7 feet 
DWM_GSIappBBr1_critique-F.doc

27

of the door. The MCNP model of the 

[Page 14 of 38]

building included this lead and it explains the significant difference between the 

measurements taken 5 feet above the floor compared to 10 and 12 feet above the floor. 

However, it was reported that the lead in the door did not exist prior to the 1971 survey or 

years later. With the conflict between verbal and written reports, the lead was removed from 

the model for estimates made in this appendix.

MCKEEL	COMMENT	to	BB.4.2 Betatron	Building	Model (part	2	pages	13-14):	

As	stated	previously,	the	statement	“The reasonable agreement between the modeled 

and measured exposure values indicates that the building model provides a realistic 

representation of the shielding presented by the new betatron building” may	apply for	

the	Co-60	source,	however, the	Betatron	building	models are	for	Betatron

x-ray	operations.	However,	close	inspection	of	the	measured	and	computer	

modeled	paired	values	in	Table	3 actually	shows	variances	ranging	between	

9.1%	and	113.6%	with	a	Mean	±	Std	Dev	percentage	=		67.5	±	27.9	S.D.	This	

level	of	agreement	lies	outside	of	the	ideal	±	10-20%	variance	between	

measured	and	modeled	computer	dosimetric	data.	McKeel	previously	

provided	three	such	references to	NIOSH	and	the	TBD-6000	WG.

•		Also, as	discussed	previously, the	Co-60	and	Betatron source	terms	are	not	

remotely	comparable	and	do	not	legitimately	substitute	for	one	another:	(a)	

the	Betatron	beam is	sharply	focused	in	contrast	to	the	omidirectional	Co-60	

radiation	pattern;	and	(b)	Co-60 gamma	sources	do	not	give	significant	

neutron	doses,	whereas	neutrons	are	an	important	constituent	of	Betatron	

beams	(~15%).	Substituting	a	Co-60	source	as	measured	data	to	validate	a	

Betatron	particle	accelerator	beam	with	x-rays,	neutrons	and	electrons	is	

scientifically	invalid.	The	fact	that	no	measurement	data	collected	at	GSI	exists	

for	either	GSI	Betatron	facility	based	on	GSI	Allis-Chalmers	24-25	Mev	Betatron	

x-ray,	neutron	or	beta	radiation	sources	needs	to	be	emphasized by	Allen.

BB.4.3 Betatron Operations External Dose Estimate 

Neutron and Gamma Dose from Scattered Radiation 

[MCKEEL	PRELIMINARY	COMMENT:	The	passages	I	wish	to	comment	upon	at	

the	end	of	this	section are	offset	in	square	brackets,	numbered	and	bolded]	for	

later	commentary.]

[1. The neutron dose rates during radiography were evaluated using MCNP] and the 

model of the new betatron building at several locations, including the control room and the 

location of the layout man. While shooting steel, the betatron was assumed to always be 

shooting a large steel object on a railcar. This angle produced the highest dose rate for the 

layout man location from several credible orientations. [2. The neutron dose rate in the 

control room and the layout man location were determined and applied for 41.43% of 

an 8 hour shift to determine the dose per shift while x-raying steel]. For uranium x-rays, 

the neutron dose rate in the control room was determined by assuming the uranium was near 
DWM_GSIappBBr1_critique-F.doc

28

the center of the shooting area and the betatron oriented away from the control room. Only 

the dose rate in the control room was calculated and adjusted to a dose per 8 hour shift of 

uranium operations. [3. The dose rate for the layout man location was not determined for 

uranium shots since for this exposure scenario it was more favorable to assume steel 

was always x-rayed]. While [4. that may appear to be inconsistent, it is actually a 

credible scenario since with two betatrons in operation, it is possible uranium was xrayed in the old betatron building while steel was being x-rayed in the new betatron 

building]. 

Gamma dose rates during radiography for the layout man location were determined in the 

same manner as the neutron. This model resulted in a dose rate of 6.67 mR/hr at the layout 

man location while the shot was in progress. [5. The layout man is assumed to be working 

100% of the time in that area and it is assumed that steel is always being shot].

Gamma Dose to Betatron Operator 

[6. For the betatron operator, gamma dose rates were determined using film badge 

data]. Workers reported that radiographers always wore film badges in the betatron building 

but with a few exceptions, detailed records of the film badge readings could not be located 

prior to 1964. The detailed records recovered from 1964 through 1973 (Landauer 1964 

through 1973) indicated badges were exchanged weekly and [7. 99.7% of them were 

recorded as “M”] which means the measured exposure was less than 10 mrem. It is possible 

for a relatively small discrete source of radiation to exist after a shot from either the material 

being x-rayed or even from activation of betatron components themselves. Because of that, it 

may be credible that an operator could be working with his back to the primary gamma 

source in the area. In order to account for this, [8. correction factors contained in ICRP 

publication 74 (ICRP 1996) were used]. This publication calculates dose to various organs 

compared per unit air kerma for several orientations. One of the organs listed in ICRP 74 is 

the breast which would be a reasonable surrogate for a film badge worn on the chest. 

Combining the breast dose conversion factor (DCF) in the posterior anterior (PA) orientation 

with the effective dose DCF in the PA orientation would provide an equivalent effective dose 

necessary to produce a 10 mrem reading on the film badge (in the PA orientation). This value 

varies with energy. [9. Table 4 provides the results of this calculation for various energy 

photons.] The effective dose for 30 keV photons was calculated to be 26 mrem based on a 10 

mrem reading on the film badges. Therefore, [10. this dose estimate will use 26 mrem per 

week as the betatron operator dose estimate which equates to an annual exposure of 

1300 mrem].

[Page 15 of 38]
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29

Neutron and Gamma Dose from Freshly Exposed Material 

Along with the exposure during an x-ray shot, layout men and betatron operators could also 

receive neutron and gamma radiation from freshly x-rayed material. [11. Gamma exposure 

to the betatron operator is accounted for with the film badge readings.] [12. Neutron 

dose from freshly exposed steel is negligible]; however, neutron dose from freshly exposed 

uranium must be accounted for to estimate the betatron operator’s dose. Also, gamma dose 

from freshly exposed steel must be accounted for in estimating the layout man’s gamma 

dose. 

For the neutron dose to the betatron operator, the uranium is assumed to be exposed to x-rays 

for 60 minutes with the operator’s exposure to the uranium starting 5 seconds after the shot 

and continuing until 15 minutes after the shot. The operators are modeled to be standing one 

foot from the uranium half of the time and one meter the remaining time. MCNP, which was 

used to calculate the neutron dose rate from the exposed uranium, found that the neutron dose 

rate decreases rapidly to essentially zero within 7 minutes following exposure. Since the 

shots lasted one hour, no buildup of neutron dose would occur from multiple shots. Using 

these assumptions, the dose from a single shot was estimated to be 0.0868 mrem. With each 

cycle taking 75 minutes (60 minutes per shot plus 15 minutes between shots) an 

[13. average of 6.4 shots could be taken in one 8 hour shift]. The dose per shift would then 

be 0.555 mrem while x-raying uranium. This value was then multiplied by the number of 

shifts per year that uranium was x-rayed to estimate the annual neutron dose to the operators 

from this source of radiation. It was added to the annual neutron dose received in the control 

room during uranium x-rays and the annual neutron dose received during steel x-rays. [14. 

The total annual neutron dose varies by year due to differing amounts of steel and 

uranium work in each year. Table 5 provides the results]. Next, the gamma dose to the 

layout man from freshly x-rayed steel was determined. [15. The gamma dose rate from 

irradiated steel decreases quickly but does not decrease to zero in minutes. Therefore, a 

buildup of radiation could occur with repeated shots causing a higher dose rate than 

would occur after only one shot. To account for this, a bounding scenario was assumed 

which includes prior shots on castings].

[Page 16 of 38]

[16. It was reported by a former supervisor that the layout man would typically spend a 

full shift marking up a large casting]. However, he might have been interrupted to mark up 
DWM_GSIappBBr1_critique-F.doc

30

a casting that had just been x-rayed. The first task was modeled as short shots on steel, 

repeated 532 times ending just at the beginning of the layout man’s shift (SCA 2014). The 

532 prior exposures are intended to be a bounding estimate. Additional analysis shows it is 

not a significant overestimate because the decreasing dose rates cause the recent shots to have 

a much larger affect than the previous shots (SCA 2008). The layout man is then assumed to 

work on this casting for a full 8 hour shift. Since marking up the steel requires close 

contact with the casting, it is assumed that the layout man is within one foot of the casting 

90% of the time and one meter from the casting the remaining 10% of the time. 

To account for the times when the layout man is interrupted to mark up a freshly x-rayed 

casting, [17. a model was developed consisting of long shots on steel]. It is assumed the 

steel was x-rayed 400 times prior to being moved to the layout man. Again, this is a bounding 

value that does not significantly affect the results. The layout man is further assumed to mark 

up the casting for one long shot cycle (75 minutes) starting 15 minutes after the shots ended 

(time to move the casting out of the betatron building). After this 75 minute exposure, it is 

assumed that another freshly x-rayed casting (shot 400 times) is moved to the layout man 

position and he works on that one for another 75 minutes. This cycle repeats continuously for 

the full 8 hour shift so it could be repeated an average of 6.4 times per shift. As with the other 

scenario, it is also assumed he spend 90% of this time within 1 foot of the casting and 

10% of the time 1 meter from the casting. 

[18. Since it was reported that the layout man would normally spend the whole shift on 

one large casting, the first scenario is assumed to account for 90% of his time and the 

repetitive scenario is assumed to account for 10% of his time].

Beta Dose 

Lastly, beta dose was evaluated for both the layout man and the betatron operator. The source 

of beta dose includes the beta dose intrinsically associated with uranium metal as well as beta 

dose from freshly x-rayed steel. The uranium metal x-rayed at GSI was cast at Mallinckrodt 

Chemical Works. [19. During recasting, decay products of uranium (notably Th-234 and 

Pa-234m), can concentrate in the outer surfaces of the cast metal. This effect has been 

reported to increase the beta dose by a factor of 10 to 15 (Putzier 1982)]. This effect is 

accounted for by assuming the Th-234 and Pa-234m activity is 15 times higher than what 

would be present at equilibrium. However, [20. the top of the castings were normally cut 

off (called a top crop) so the metal sent to GSI is assumed to have been cropped and 

only the sides would have the concentrated decay products]. The concentration on the top 

and bottom is assumed to be at an equilibrium concentration. 

[21. MCNP was used to model an 18 inch diameter ingot. The dose rate at one 

centimeter, one foot and one meter from the surface were calculated]. These dose rates 

were calculated both as a distance from the top and a distance from the side. It was assumed 

that the operator was equally likely to be in front of the top or the side of the ingot. 

Therefore, the two dose rates at each distance were averaged. The betatron operator is 

assumed to spend half of his time one foot from the uranium and the remaining time at a 

distance of one meter. While the operator is within one foot, his hands and forearms are 

assumed to be one centimeter from the uranium (essentially in contact). 

[Page 17 of 38]
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31

Based on the shot scenario for uranium, an average of 6.4 shots per 8 hour shift could be 

performed. Exposure time near the uranium would be 20% of the time (15 minutes out of 75 

minutes). [22. Therefore the betatron operator average beta dose from uranium 

operations is estimated at 39.5 mrad per shift to the whole body and 621 mrad per shift 

to the hands and forearms]. 

In considering beta dose from freshly x-rayed steel castings, it is important to realize shots 

were overlapped in order to get full coverage of the casting. Also, defects were repaired and 

reshot. It was reported that the same casting could be returned to the betatron building 5 to 10 

times before leaving the site. Therefore, it is possible for the same location to be x-rayed 

multiple times. [23. This estimate assumes the same location was x-rayed 30 times (and 

average of 7.5 trips to the betatron and assumed 4 overlapping shots each time)]. It 

should be noted that for long shots, this would be 30 hours of shooting in the same spot while 

short shots would be 1.5 hours. [24. However, because many of the nuclides formed are 

relatively short lived], the dose estimate after 1 hours of shooting is approximately 92% of 

the estimate after 30 hours of shooting. Because the difference is small and because it is 

impossible to know the exact number of times each location was shot, this estimate assumes 

each steel casting was shot for 30 hours prior to being handled. 

In order to calculate the beta dose from freshly x-rayed steel, the [25. chemical composition 

of HY-80 steel was modeled with MCNP] in order to calculate the production rate of 

residual nuclides in the steel. From the list of nuclides produced, those that were not 

radioactive and those that do not emit a beta particle were eliminated. 

This production rate was used to calculate the average concentration throughout the depth of 

the steel of each residual nuclide based on that nuclides half-life and the shot duration. 

However, the intensity of the betatron beam would decrease with its depth in the steel 

causing the highest concentrations to be near the surface. Averaging the nuclide 

concentration over a thick target would dilute the surface concentration. To avoid this, the 

surface activity concentration was determined for each nuclide using the mass attenuation 

coefficient for HY-80 steel corresponding to the maximum photon energy from the 

betatron. This surface activity was the initial surface activity at the time the shot ended. Since 

some nuclides could decay quickly during the time the operators would be exposed, the 

nuclides with the highest initial activity may not produce the highest integrated dose. To 

account for this, the integrated activity from zero to 15 minutes after the shot was then 

calculated to provide an indication of the integrated dose. [26. Six nuclides produced over 

99% of the total time-integrated activity so these six were used for the remainder of the 

analysis.]

[27. For each of the six nuclides, the surface activity concentration was assumed to be 

the same for the entire depth of a thin HY-80 steel object. MCNP was then used to 

calculation] the initial beta dose rate at 1 centimeter, 1 foot and 1 meter from the object. 

These dose rates were then integrated between 5 seconds and 15 minutes for the long shots 

and 5 seconds and 12 minutes for the short shots. The time-integrated dose for each nuclide 

was then summed to calculate the total beta dose per shot at these distances. 

[Page 18 of 38]
DWM_GSIappBBr1_critique-F.doc

32

[28. Lastly, the betatron operator was assumed to be 1 foot from the object for half of 

the time he was exposed and 1 meter from the object for the remainder of the time.] His 

hands and forearms are assumed to be 1 centimeter half the time and 1 meter the remaining 

time. Also, the operators could participate in an average of 32 short shots in one 8 hour shift 

or an average of 6.4 long shots. The short shots accounted for 90% of the shots, which would 

mean 36% of the time the operators were working on long shots and 64% of the time they 

were working on short shots. This information was combined to calculate a beta dose per 8 

hour shift to the whole body and separately to the hands and forearms. That dose was 

multiplied by the number of shifts per year an operator was working with steel. 

[29. For the layout man, the same process was used but the scenario was altered]. The 

scenario matched the scenario used to calculate the gamma dose to the layout man from 

irradiated steel. For the one large casting that was worked most of the shift, it was assumed 

the casting was x-rayed 532 times prior to the layout man marking up the casting. The layout 

man is assumed to work on this casting for the full 8 hour shift starting 15 minutes after the 

x-rays ended. This then produced a dose per shift since the single casting was worked on the 

entire shift. 

[30. For the interrupted scenario, it is assumed the casting was x-rayed 400 times in the 

long steel shot scenario prior to the layout man working on the casting.] In this case, the 

layout man is assumed to work on the casting for 75 minutes starting 15 minutes after the xrays ended. By repeating this cycle, the layout man could work on an average of 6.4 such 

castings throughout the course of an 8 hour shift. 

Just as with the gamma dose estimate, it is assumed the operator worked 1 foot from the 

casting 90% of the time and 1 meter from the casting the remaining 10% of the time. For beta 

dose, it was also assumed his hands and forearms were 1 centimeter from the casting while 

the rest of his body was 1 foot from the casting (90% of the time). Also as with the gamma 

dose estimate, the single casting scenario is assumed to take 90% of the operator’s time while 

the repetitive scenario takes the remaining 10% of his time. 

[31. Table 5 and 6 include the annual dose estimates from all sources for the betatron 

operator and the layout man respectively.]

[Page 19 of 38]
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33

MCKEEL	COMMENT	to BB.4.3	Betatron	Operations	External	Dose	Estimate:

A	general	observation	for	this	section is	that	much	of	the	data	and	many	of	the	

cited	conditions	are	unfamiliar	to	McKeel.	Were	all	of	the	data	elements	and	

methodology	developed	by	NIOSH	and	presented	to	the	TBD-6000	WG	in	

white	papers,	and,	if	so,	what	are	the	specific	reference	citations?	Similarly,	

did	SC&A	review	and	report	on	all	this	NIOSH	data	and	methodology?	That	is,	

is	Allen	presenting	any	of	this	information	for	the	first	time	in	AppBBr1?

[1.	The	neutron	dose	rates	during	radiography	were	evaluated	using	MCNP]	--

Mr.	Allen	needs	to	specify	which	version	of	MCNP,	and	the	date	of	that	version,	

was	used	for	this	neutron	analysis. What	measured	Betatron	neutron	data	was	

used	to	validate	the	MCNPx	computer	model?	Was	the	agreement	±	10	to	20%?

[2.	The	neutron	dose	rate	in	the	control	room	and	the	layout	man	location	were	

determined	and	applied	for	41.43%	of	an	8	hour	shift	to	determine	the	dose	per	

shift	while	x-raying	steel]	-- Allen	fails	to	mention	the	fact	that	SC&A	modeled	

the	highest	neutron	flux	in	the	Betatron	control	room,	a	paradoxical	result	
DWM_GSIappBBr1_critique-F.doc

34

because	the	control	room	was	supposed	to	be	where	the	operators	were	the	

safest.	One	reason	the	control	room	values	were	so	high	may	be	the	door	was	a	

flimsy	standard	steel	office	door.	The	door	shielding	of	the	Betatron	facility	at	

Milwaukee	School	of	Engineering	(MSOE), which was	donated	to	the	school	by	

Allis-Chalmers,	weighed	70	tons and	was	filled	with	steel	balls.	We	infer	the	

GSI	control	rooms	were	poorly	shielded	and	the	workers	poorly	protected.	

The	GSI	expert	team	made	these	facts	known	to	NIOSH,	Allen	and	the	TBD6000	WG	and	Board	through	direct	testimony	and	white	papers.	HASL in	

NYO-4699(Suppl.	1) also	reports	some	of	the	highest	detected	doses	for	

photons	and	neutrons	near	a	similar	ordinary	steel	control	room	door	at one	

of	the	three	analyzed	22	Mev	betatron	facilities.

• Mr.	Allen	needs	to	specify	which	version	of	MCNP,	and	the	date	of	that	

version,	was	used	for	this	neutron	analysis.	What	measured	Betatron	neutron	

data	was	used	to	validate	the	MCNPx	computer	model?	Was	the	agreement	±	

10	to	20%?

[3.	The	dose	rate	for	the	layout	man	location	was	not	determined	for	uranium	

shots	since	for	this	exposure	scenario	it	was	more	favorable	to	assume	steel	was	

always	x-rayed]	-- I	cannot	understand	what	this	sentence	means.	OCAS-IG-003	

mandates	that	all	radiation	sources	must	be	addressed	and	the	doses	

bounded. Without	specific	supporting	data,	the	phrase “...it	was	more	favorable	

...”	is	meaningless.	Also,	which	dose	rate	is	being	referred	to?	Is	the	dose	rate	

for	x-ray	photons	or	for	neutrons?	Where	is	this	data	specifically	cited	and	

referenced	in	white	papers	or	WG	or	Board	transcripts? What	were	the	

respective	x-ray	photon	and/or	neutron	dose	rates	for	uranium	and	steel	that	

allows	Allen	to	state	steel	was	more	favorabe?	The	exact	report	pages	with	a	

link	to	the	citation should	be	provided. This	DR	guidance	document	should	

stand	by	itself	as	a	primary	information	source	without	relying	on data	in	any	

other	publication. The	relevant	data	needs	to	be	extracted/stated	in	AppBBr1.

[4.	that	may	appear	to	be	inconsistent,	it	is	actually	a	credible	scenario	since	

with	two	betatrons	in	operation,	it	is	possible	uranium	was	x-rayed	in	the	old	

betatron	building	while	steel	was	being	x-rayed	in	the	new	betatron	building]	--

Allen	supports	a	fact	that	McKeel	makes	elsewhere	in	this	document.	The	GSI	

Old	Betatron	building	(OBB)	was	located	only	300	feet	away	from	the	New	

Betatron	facilty.	The	OBB	had	a	sign	attached	to	the	outside	of	it:	“DO	NOT	

APPROACH	THIS	BUILDING	WITHIN	100	FEET.”	The	same	caveat	presumably	

applied	to	the	New	Betatron	buiding	(NBB).	Thus,	according	to	GSI	signage,	the	

radiation	fields	surrounding	the	OBB	and	NBB	 nearly	overlapped.	No	actual	

GSI	radiation	measurements	that	led	to	the	posting	of	the	signage	exists	today.	

NIOSH	never	modeled	the	stray	radiation	that	the	many	GSI	workers	received	

while	traversing	the	road	and	railroad	tracks	and	crowded	space	that	lay	

between	the	OBB	and	NBB.	That	space	included	a	road	that	was	used	daily	by	

practically	all	personnel	who	drove	to	the	GSI	facility	at	1417	State	Street.

Railroad	operators	and	outdoor	crane	operators	and	chainmen	also	worked	in	

the	space	between	OBB	and	NBB.	Many	cars	were	parked	in	that	area	as	well.
DWM_GSIappBBr1_critique-F.doc

35

[5.	The	layout	man	is	assumed	to	be	working	100%	of	the	time	in	that	area	and	

it	is	assumed	that	steel	is	always	being	shot]	-- The	basis	for	this	assumption	is	

not	clear.	Allen	should	clarify	the	supporting	evidence.

[6.	For	the	betatron	operator,	gamma	dose	rates	were	determined	using	film	

badge	data]	-- See	discussion	under	item	#7	(above).	The	Neton	memo	of	

December	19,	2013	stated	that	NIOSH	will	not	make	use	of	GSI	Landauer	film	

badge	data in	AppBBr1.	This	passage	is	a	direct	violation	of	that	on-the-record	

NIOSH	policy	statement.

[7.	99.7%	of	them	were	recorded	as	“M”]	--

(a)	The	discussion	of	GSI	Landauer	film	badge	applications	and	data	is	

moot	and	should not	be	part	of	AppBBr1	(6/6/14) because,	as	Dave	Allen	

knows,	the	December	19,	2013	Jim	Neton/DCAS	memo	written	about	the	

Hinnefeld-Yoder	DCAS-Landauer	interactions	led	NIOSH	to	declare	it	would	

not	use	GSI	Landauer	film	badge	data	because	of	discrepancies	in	the	way	

Landauer	handled	“control”	values	and	subtracted	background.	This	memo	

was	documented	in	the	Dec.	5,	2013	GSI	Appendix	BB	SC&A-prepared	issues	

matrix.	McKeel	filed	a	FOIA	request	through	the	CDC/ATSDR	Atlanta	FOIA	

office	to	obtain	all	related	emails	and	McKeel	received	only	a	subset.	The	

Yoder-Hinnefeld	e-mails	and	some	related	records	were	withheld	from	him	

with	no	specific	exemptions	being	cited.

•	ALLEN	DOES	NOT	MENTION	THIS	CRUCIAL	MEMO	OR	THE

NIOSH/DCAS ABANDONMENT	OF	GSI	LANDAUER	FILM	BADGE	DATA	IN	

APPENDIX	BB	REV	1	(JUNE	6,	2014).	This	is	a	most	serious	and	concerning	

omission.	It’s	absence	in	the	GSI	SEC	co-petitoner’s	opinion	totally	invalidates	

all	sections	of	AppBBr1	that	mention	Landauer	film	badge	data	or	uses.

(b)	NIOSH	and	SC&A	have	never	subjected	their	complete	Landauer	GSI	

#2084	film	badge	datasets	to	independent	review.	The	GSI	expert	team	does	

have	independent	knowledge	of	discrepancies	within	this	dataset	from	

reviewing	a	subset	of	year-end	reports	given	to	McKeel	unredacted	by	

Landauer	in	January	2007,	by	reviewing	individual	GSI	radiographer	

Landauer	and	NCC/GSI	records	files,	and	by	reading	NIOSH	and	SC&A	white	

papers	about	their	respective	Landauer-GSI	datasets	that	differ	from	each	

other	in	significant	respects.	In	addition,	the	sole	radiographer	who	provided	

the	fragmentary	1963	and	1962	18	quarter	Pittsburgh	Testing	and	GSI	FB	data	

sheets	is	missing	all	of	his	1966	Landauer	FB	data	except	for	a	single	sheet	

obtained	through	a	PA/FOIA	request.	The	GSI	SEC	co-petitioner	challenges	the	

accuracy	of	this	statement	that	99.7%	of	all	GSI	radiographer	photon	data	was	

“M.”	I	have	outllined	the	majority	of	my	FB	evidence	in	McKeel	white	papers.

[8.	correction	factors	contained	in	ICRP	publication	74	(ICRP	1996)	were	used]	--

Allen needs	to	define	exactly	which	“correction	factors”	were	used	and	note	

the	pages	on	which	the	conversion	factor	data	are	listed.
DWM_GSIappBBr1_critique-F.doc

36

[9.	Table	4	provides	the	results	of	this	calculation	for	various	energy	photons.]	--

Table	4	is	labeled	“effective	Dose	for	Film	badge	readings	at	various	doses.”

Allen	should	state	the	exact	citation	(page	number)	in	the	referenced	

publication.

[10.	this	dose	estimate	will	use	26	mrem	per	week	as	the	betatron	operator	dose	

estimate	which	equates	to	an	annual	exposure	of	1300	mrem] -- An	invariant	

external	dose	estimate	of	26	mrem	per	week	for	Betatron	operators	is	

absurdly	low	based	on	2008	MCNP	calculations	by	NIOSH	and,	especially	by	

SC&A.	These	2008	data	did	not	include	use	of	GSI	landauer	film	badge	data.	

Due	to	the	Neton	memo	and	NIOSH’s	decision	not	to	use	Landauer	FB	data	at	

GSI,	the	2008	SC&A	Betatron	dose	assignments	need	to	become	the default	

values	in	AppBBr1.	Allen	may	not	use	Landauer	film	badge	data	in	any	of	his	

AppBBr1	dose	calculations	as	a	categorical	statement	based	on	his	employer’s	

on	the	record	policy to	ban	use	of	GSI	Landauer	FB	data	in	AppBBr1.

•		Footnote:	NIOSH	could	still	utilize	NYO-4699(Suppl.	1)	surrogate	photon	and	

neutron	data	measured	by	HASL	in	their	AEC	Accelerator	Survey	Program	

from	three	22	Mev	betatrons	of	the	same	vintage	as	the	two	GSI	A-C	Betatrons.	

NIOSH	and	the	Board	previously	rejected	using	this	data	that	was	

recommended	for	use	by	the	SINEW	GSI	expert	team.	We	regard	not	using	this	

unique	NYO-4699	measured	Betatron	data	to	be	a	serious	scientific	error	of	

omission on	the	parts	of	NIOSH,	the	Board	and	its	contractor	SC&A.

[11.	Gamma	exposure	to	the	betatron	operator	is	accounted	for	with	the	film	

badge	readings.]	-- NIOSH	announced	policy	in	the	Neton	December	2013	

memo	was	that	NIOSH will	NOT	use	GSI	Landauer	#2084	program	film	badge	

data	in	AppBBr1	for	future	dose	reconstructions	or	reworked	DRs.	This	

section	needs	to	be	modified	or	retracted.

[12.	Neutron	dose	from	freshly	exposed	steel	is	negligible] -- Allen	limits	his	

analysis	to	freshly	exposed	steel.	However,	many	(unknown	percent)	of	GSI	

Betatron	NDT	shots	were	repeated	shots	on	very	large	castings	that	might	

require	400	exposures	and	10,000	R	being	delivered	to	capture	an	x-ray	image	

array	that	covered	the	entire	casting.	Such	simplistic	analyses	(a)	are	not	

claimant	favorable,	(b)	underestimate	neutron	exposures and	large	casting	

activation	products,	and	(c)	fail	to	conform	to	reality.	NO	radiation	dose	is	

negligible	from	a	cancer	risk	perspective	using	the	worldwide	accepted

“linear	no	threshold”	statndard	for	radiation	safety.	All	radiation	doses	are	

cumulative	and	additive.	The	BIER	VII	report	for	the	first	time	confirms	that	

chronic,	very	low	levels	of	diagnostic	x-rays	significantly	increase	the	risk	of	

developing	a	future	cancer.	

[13.	average	of	6.4	shots	could	be	taken	in	one	8	hour	shift]	-- Again,	these	

assumptions	are	based	on	testimony	from	one	of	three	GSI	radiographers	who	

testified	about	Betatron	MCW	uranium	shots.	There	is	testimony	that	more	
DWM_GSIappBBr1_critique-F.doc

37

than	6.4	shots	could	be	delivered	in	1	hour.	For	example,	4	corner	shots	at	

each	end	of	the	dingot/ingot	uranium	were	described	that	could	be	done	in	

rapid	succession	minus	any	added	layout	time.	The	metal	might	have	to	be	

rotated	into	position	with	the	Betatron	room	overhead	crane.	The	6.4	shots	

per	8	hour	shift	are	too	few	and	the	low	number	is	not	claimant	favorable.	

[14.	The	total	annual	neutron	dose	varies	by	year	due	to	differing	amounts	of	

steel	and	uranium	work	in	each	year.	Table	5	provides	the	results] -- NIOSH	and	

SC&A	and	the	TBD-6000	WG	have	no	way	of	knowing	the	total	steel	castings	

tonnage	or	volume	or	number	of	shots	or	castings	that	were	shot	at	GSI	each	

year.	The	MCW	purchase	orders	merely	outline	a	plan;	they	do	not	substitute	

for	lost	or	destroyed	GSI	shot	logs	and	shipping	manifests	and	x-ray	report

records	and	Betatron	log	books, none	of	which	NIOSH	sought	or	had	in	their	

possession.	The	amount	of	steel	subjected	to	Betatron	NDT	at	GSI	is	a	pure	

guess. Note that	GSI,	according	to	plant	metallurgists	interviewed	by	the	

SINEW	GSI	expert	team,	did	Betatron	NDT	radiography	work	on	dozens of	

types	of	steel	and	alloyed	steel	products,	HY-80	being	but	one	of	them.	Also,	

the	chemcial	composition	of	different	types	of	alloy	steel	changed	over	time.

[15.	The	gamma	dose	rate	from	irradiated	steel	decreases	quickly	but	does	not	

decrease	to	zero	in	minutes.	Therefore,	a	buildup	of	radiation	could	occur	with	

repeated	shots	causing	a	higher	dose	rate	than	would	occur	after	only	one	shot.	

To	account	for	this,	a	bounding scenario	was	assumed	which	includes	prior	

shots	on	castings]	-- Allen	is	correct.	Activated	steel	and	chronically	activated	

CONCRETE	forming	the	Betatron	shooting	room	walls	would	emanate	

secondary	(scattered,	activated)	photons	and	neutrons	that	must	be, but	have	

not	been,	bounded	by	NIOSH	in	AppBBr1.	Allen	should	provide	a	specific	

reference	to	a	directly	related	source	WG	transcript with	date	and	pages that	

details	the	methodology	described	in	this	section.

[16.	It	was	reported	by	a	former	supervisor	that	the	layout	man	would	typically	

spend	a	full	shift	marking	up	a	large	casting]	-- Elsewhere	Allen	surmises	that	

only	10%	of	Betatron	shots	were	“long	shots.”	Thus,	the	dose	calculation	

should	be	based	on	the	90%	of	“shorts	shots”	and	the	two	results	added	

because	individual	GSI	radiographers	did	both	types	of	work.	They	also	

accumulated	photon	external	doses	resulting	from	work	exposures	to	other	

portable	GSI	NDT	sources	(conventional	x-ray,	Ra-226	(1952-62),	Ir-192,	Co60), which	should	be	added	to	their	Old	and	New	Betatron	doses	to	serve	as	

IREP	total	dose	input.	I	perceive	this	is	not	the	way	GSI	DRs	have	been	carried	

out	to	date.	The	Dose	Reconstruction	subcommittee	of	the	ABRWH	should	

investigate	this	matter	if	and	when	they	review	any	completed	GSI DRs.	

[17.	a	model	was	developed	consisting	of	long	shots	on	steel]	-- Where	is	this	

model	reported:	Allen	should	cite	WG	meeting	transcript	date	and	pages?

[18.	Since	it	was	reported	that	the	layout	man	would	normally	spend	the	whole	
DWM_GSIappBBr1_critique-F.doc

38

shift	on	one	large	casting,	the	first	scenario	is	assumed	to	account	for	90%	of	his	

time	and	the	repetitive	scenario	is	assumed	to	account	for	10%	of	his	time]	--

This	represents	spurious	reasoning	on	the	part	of	Mr.	Allen.	Layout	work	on	

huge	castings	that	required	an	entire	shift	was	unusual. There	is	no	

documentation	of	who	made	this	statement,	or	the	data	he	was	relying	on	to	

make	this	questionable	assertion,	and	the	statement	defies	common	sense	and	

what	is	known	by	the	GSI	expert	team	about	GSI	work	practices	by	

radiographers. It	is	likely	the	repetitive	scenario	occupied	a	far	greater	

fraction	of	a	Layout	man’s	total	work	effort.	Allen	needs	to	explicitly	cite	and	

reference	the	person,	time	and	transcript	pages	or	affidavit number	and	

source	documents that	support the initial	contention	Allens	alludes	to	that	

Layout	men	spent	90%	of	their	8	hour	shift	laying	out	single	castings.	I	do	not	

believe	the	evidence	I	know	supports	this	simplifying	assumption,	which	is	

akin	to	a	guesstimate by	one	anonymous	GSI	worker. There	is	no	record	of	this	

“fact”	in	the	NRC	FOIA	2010-0012	license	documents	I	am	aware	of.

[19.	During	recasting,	decay	products	of	uranium	(notably	Th-234	and	Pa234m),	can	concentrate	in	the	outer	surfaces	of	the	cast	metal.	This	effect	has	

been	reported	to	increase	the	beta	dose	by	a	factor	of	10	to	15	(Putzier	1982)] --

Where	(what	pages)	of	the	long	referenced	book	that	is	Reference	25	contains	

the	description	of	the	“putzier	effect?”	Allen	cites	the	year	1982	twice	but	fails	

to	note	the	specific	pages	that	describe	the	Putzier	effect.	What	is	the	complete	

citation,	please?

[20.	the	top	of	the	castings	were	normally	cut	off	(called	a	top	crop)	so	the	metal	

sent	to	GSI	is	assumed	to	have	been	cropped	and	only	the	sides	would	have	the	

concentrated	decay	products]	-- The	direct	eyewitness	and	written	and	

photographic	evidence	the	GSI	expert	team	is	aware	of	refutes	this	

unsupported	statement	by	Allen.	All	evidence	I	am	aware	of,	in	fact,	shows	that	

only	intact,	uncropped	uranium	dingots	and	ingots	were	shipped from	MCW	to	

GSI.	MCW	documents	show	that	other	(not	sent	to	GSI)	Ur	ingots	were top	

cropped	after	being	removed	from	the	bomb.	Where	is	Mr.	Allen’s	proof	of	this	

statement of	the	cropped	status	of	MCW	GSI Ur	ingots	and	dingots? To	be	

explicit,	we	also	believe	repeated	assertions	by	SC&A’s	Bill	Thurber	that	

cropping	always	occurred	as	the	ingots	or	dingots	were	removed	from	the	

bomb	is	NOT	true	in	the	case	of	uranium	metal	forms	bound	for	GSI.	The	fact	

is,	no	one	knows	the	answer	to	this	question.	Many	GSI	workers	testified	the	

MCW	uranium	had	“rough	surfaces”	all	over.	This	is	consistent	with	

uncropped	surfaces.	Newly	exposed	pure	uranium	cut	surfaces	are	shiny	and	

smooth,	not	dull	and	shaggy	as	was	described	for	the	U-238	that	was	shipped	

to	GSI.	Allen	makes	many	such	unsupported	and	challengeable	assumptions	in	

AppBBr1	that	we	believe	have	no	place	in	a	scientific	document	where	

observations	must	be	supported	by	discrete	reference	citations.	Allen	either	

needs	to	provide	such	documentation	or	retract	this	assumption	that	Ur-238	

ingot/dingot	cropping	had	aways	occurred	before	shipment	to	GSI.
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39

[21.	MCNP	was	used	to	model	an	18	inch	diameter	ingot.	The	dose	rate	at	one	

centimeter,	one	foot	and	one	meter	from	the	surface	were	calculated]	-- GSI	also	

worked	with	rough	surfaced	U-238	MCW	dingots,	billets	(in	1952)	and	

betatron	slices	made	at	MCW.	They need	to	be	modeled	separately	in	MCNP.

[22.	Therefore	the	betatron	operator	average	beta	dose	from	uranium	

operations	is	estimated	at	39.5	mrad	per	shift	to	the	whole	body	and	621	mrad	

per	shift	to	the	hands	and	forearms]	-- This	comment	also	applies	to	item	23	

below.	Beta	skin	doses	were	calculated	first	by	SC&A	and	later	by	NIOSH	

almost	as	an	afterthought	in	2014	essentially	after	the	TBD-6000	WG	had	

finished	its	work	on	GSI matters.	Has	all	of	this	beta	skin	dose	data	been	

calculated	on	the	record	in	DCAS	white	paper	reports? If	the	answer	is	YES,	then	

would	Allen	please	give	a	detailed	methods	reference	as	to	the	source	report	

author(s),	number,	date	and	pages?

[23.	This	estimate	assumes	the	same	location	was	x-rayed	30	times	(and	

average	of	7.5	trips	to	the	betatron	and	assumed	4	overlapping	shots	each	

time)]	-- See	comment	to	item	22. A	detailed	citation	by	Mr.	Allen	to	this	

methodology	is	needed.

[24.	However,	because	many	of	the	nuclides	formed	are	relatively	short	lived]	--

Allen	misses	the	point,	the	major	x-ray	and	neutron	exposure	was	from	the	

other longer	lived	nuclides	caused	by	betatron	activation	and	fission	of	

uranium	and	betatron	activation	of	various	types	of	steel.

[25.	chemical	composition	of	HY-80	steel	was	modeled	with	MCNP]	-- Modeling	

one	type	of	steel	out	of	dozens	of	types	used	at	GSI	is	insufficient.

[26.	Six	nuclides	produced	over	99%	of	the	total	time-integrated	activity	so	

these	six	were	used	for	the	remainder	of	the	analysis.]	-- Allen	needs	to	identify	

the	six	nuclides	and	state	their	fractional	amounts	based	on	specific	

radioactivity	and	give	their	radionuclide	half-lives.	

[27.	For	each	of	the	six	nuclides,	the	surface	activity	concentration	was	assumed	

to	be	the	same	for	the	entire	depth	of	a	thin	HY-80	steel	object.	MCNP	was	then	

used	to	calculation]	-- “The	word	“calculation”	should	be	“calculate.”	What	

distance	below	the	surface	was	modeled	with	MCNP? Allen	provides	almost	no	

details	of	NIOSH’s	extensive	MCNPx	modeling with	respect	to	software	version,	

parameters	and	assumptions	used, or	what	was	measured	(photons,	neutrons,	

electrons	[beta],	alpha). If	SC&A	input	data	was	used,	that	information	should	

be	appended.

[28.	Lastly,	the	betatron	operator	was	assumed	to	be	1	foot	from	the	object	for	

half	of	the	time	he	was	exposed	and	1	meter	from	the	object	for	the	remainder	of	

the	time.]	-- Why	do	these speculative	and	arbitrary	NIOSH assumptions	make	

sense?	The	claimant	favorable	assumption	would	be	the	betatron	operators	
DWM_GSIappBBr1_critique-F.doc

40

were	1	inch	from	the	target	object	(casting,	uranium	metal)	during	the	entire	

time.

[29.	For	the	layout	man,	the	same	process	was	used	but	the	scenario	was	

altered]. The	claimant	favorable	assumption	would	be	the	layout	men	were	

1	inch	from	the	target	object	(casting,	uranium	metal)	during	the	entire	time.

•		Has	this	methodology	been	described	in	a	WG	meeting,	a	white	paper,	or	a	

Board	meeting?	Has	SC&A	reviewed	the	methodology	on	the	written	record	in	

Docket	140	(GSI)?	If	the	answers	are	Yes,	then	Mr.	Allen	should	provide	direct	

references	to	the	transcript	date	and	pages	that	support	his	AppBBr1	DR	

methods.	

•		I	believe	the	overriding	assumption	is	that	ALL	AppBBr1	NIOSH	dose	

reconstruction	methodology	in	all	sections	has	been	reviewed	and	approved	

by	SC&A,	the	TBD-6000	WG	and	the	full	Board.	Proof	that	this	has	occurred	

should	be	provided	by	Allen	and	DCAS/NIOSH	in	all	sections	of	AppBBr1.	

•		I	will	state	again	that	major	parts	of	some	sections	in	AppBBr1	appear	to	

Dan	McKeel,	as	part	of	the	GSI	expert	team	and	GSI	SEC-00105	co-petitioner,	to	

have	been	inserted	for	the	first	time.	That	observation	prompted	comment	29.

[30.	For	the	interrupted	scenario,	it	is	assumed	the	casting	was	x-rayed	400	

times	in	the	long steel	shot	scenario	prior	to	the	layout	man	working	on	the	

casting.] -- Perhaps	I	misunderstand	the	English,	but	this	assumption	appears	

to	an	absurdity.	Layout	men	layout	by	necessity	(and	logic)	marked	castings	

before, not	after, the	castings	are	x-rayed	with	the	GSI	Betatrons.

[31.	Table	5	and	6	include	the	annual	dose	estimates	from	all	sources	for	the	

betatron	operator	and	the	layout	man	respectively.]	--

(a)	McKeel	Comment	on	Table	5	-- GSI	Betatron	operator	dose	

summary: The	external	dosimetry	data	in	this table	lacks	face	validity	for	

several	reasons,	as	follows:

ERROR	#1:	No	data	at	all	exists	for	other	production	activities	at	GSI	

with	respect	to	MCW	uranium	apart	from	the	three	NIOSH/McKeel	DOE	

operational	reports	that	led	to	an	extension	of	the	covered	period.	Thus,	these	

back	extrapolations	are	invalid.	With	respect	to	photons	while	x-raying	and	

from	uranium,	for	example	(columns	3	and	4), GSI	did	R&D	image	

improvement	“research” on	uranium-238	billet	sections	that	was	different	

from	production	Betatron	MCW	uranium	NDT	work	in	later	years	;

ERROR	#2:		The	neutron	data	was	erroneously	not	compared	to	

NYO4699	(Suppl.	1)	measured	neutron	data	and	was	not	validated	for	MCNPx;

ERROR	#3:	The	column	6	gamma	dose	assigned	in	all	years	of	1300	

mrem/yr	is	based	on	NIOSH	normalizing	Betatron	data	using	Landauer	film

badge	data	that	was	declared invalid	by	Neton/NIOSH	in	his	12/19/13	

emailed	memo	(see	PAGES 13-15). The	values	are	grossly	different	by	~	8-fold	

from	NIOSH	2007-2008	gamma	photon	external	dose assigned	to	Betatron	

operators	in	AppBBr0.	Allen	fails	to	acknowledge	this	central	fact.	Also,	a	
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41

contant	gamma	dose	in	the	face	of	changing	production	rates	at	GSI	leading	to	

closure	in	1973	lacks	statistical	face	validity.	The	assigned	value	is	not	

plausible	or	claimant	favorable	or	scientifically	defensible.	This	is	especially	

so	because	of	the	variable	values	assigned	to	highly	variable	neutron	and	beta	

doses	in	columns	2,	3,	4,	7	and	8.

ERROR	#4.	Most	implausible	are	the	sharply	declining	neutron	doses	

listed	in	columns	3	and	4	for	1963-1966.

(b)	McKeel	Comment	on	Table	6	-- GSI	Layout	man	dose	summary:

Allen	erroneously	states	that	layout	work	could	not	have	been	done	in	the	Old	

Betatron	tunnel	or	just	outside.	Worker	testimony	(Dave	Woodard)	indicates

that,	in	fact,	some	layout	work	near	or	inside	the	Old	Betatron	facility	in	the	

tunnel	and	shooting	room	and	just	outside	did	take	place.	He	was	on	rail	cars	

that	backed	up	inches	away	from	the	Old	Betatron	ribbon	door	while	shots	

were	occurring	inside	in the	shooting	room.	Another	unknown	fraction	of	the	

Old	Betatron	layout	work,	presumably	on	the	massive	castings.	was	done	in	

Building	10	before	the	castings	were	returned	to	the	Old	Betatron.	Workers	

describe	a	constant	supervisory	imperative	to	expedite	“hot”	or	rush	NDT	

castings	work.	Rush	“hot	job”	work would	not	include	a	trip	back	to	Bldg.	10	

for	further	layout	markups.	The	layout	was	done	in	or	near	the	Old	Betatron	

building.	TABLE	6	needs	to	be	expanded	to	include	layout	man	exposures	in	

the	Old	Betatron	facility	based	on	this	information.

BB.4.4 External Dose Estimate for Isotope Source Operations 

[1. Radium-226 Radiography]

Prior to 1963, GSI used two Ra-226 sources for radiography. These sources were 500 mg 

(500 mCi) each (AEC 1962, pg. 9). The sources were reported to have been held in a 

container that looked like a plumb bob (see figure 6 for an example of such a container). 

According to GSI’s AEC license application in 1962, the Ra-226 sources were used with the 

“fishing pole” technique. This technique involves attaching the source to the end of a string 

and attaching the other end of the string to the end of a pole in a configuration that resembles 

a fishing pole (figure 7). A former operator indicated the shot was set up so that the film was

in place and a small cup was positioned where the source was to be placed. The operator then 

moved the source from a shielded container to the cup using the fishing pole where it was 

placed for the duration of the shot. When the desired exposure time was achieved, the

[Page 20 of 38]

process was reversed to remove and store the source. The operator reported that the pole was 

4 to 6 feet long and it took 12 to 15 seconds to place the source (DCAS 2011). Assuming the 

midpoint distance of 5 feet and the midpoint time of 13.5 seconds the dose to the operator for 

placing the source would be 0.67 mR. He would receive the same dose again when removing 

the source so his total dose per shot would be 1.33 mR.
DWM_GSIappBBr1_critique-F.doc

42

Close up photograph of source container commonly used for industrial radiography radium 

sources

Photograph of a man performing radiography using the fishing pole technique

[Page 21 of 38]
DWM_GSIappBBr1_critique-F.doc

43

[2. A special radiography room was built within the #6 building]. The room measured 22 

feet by 60 feet and contained a separate room for the operators as well as armor steel plates 

for shielding (AEC 1962 pg 8 & 9). The [3. walls of the room were constructed with 24” 

thick sand filled concrete blocks]. The top of the room was open to allow an overhead crane 

to lower items into the room. Figure 8 provides a drawing of this room. Former workers at 

GSI also reported that the sources were sometimes used outside of the radiography room. 

They reported that, when that occurred, they would rope off an area 1.5 times the required 

distance. Additionally, it was reported that the radiographers would leave the area unattended 

at times and other people would then ignore the boundary and walk through the area 

(Transcript 2009; pg 137).

[3. Drawing of the radiography room in the number 6 building from AEC license 

documentation]

In addition to receiving a radiation dose while placing and removing the source, when 

working outside the radiography room, radiographers would also receive a dose while 

waiting at the boundary. [4. A boundary was reportedly set up at 1.5 times the required 

distance. The required distance would be the point where the radiation levels fell below 

2 mR/hr.] One and a half times this distance would set the boundary at a dose rate of 0.89 

mR/hr. Assuming the radiographer stayed at the boundary for the duration of the shot, an 

additional dose would be received. To estimate that dose, it is first necessary to determine 

how many shots were taken and the total duration of those shots. 

[Page 22 of 38]

No direct records were found as to how often the radium sources were utilized at GSI (such 

as a shot log), however, some indirect information does exist. In 1962, GSI transitioned from 
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44

using two 500 mg Ra-226 source to using two small Co-60 sources. The stated purpose for 

the transition was a State of Illinois request that GSI stop using the radium sources (Kleber 

1962). Some key dates associated with the transition are: 

• 3/7/1962 Applied for an AEC source license (Kleber 1962) 

• 4/18/1962 License granted by the AEC (AEC 1962 pg 2) 

• 5/21/1962 Purchased two Co-60 sources (AEC 1962a, pg 3) 

• 6/24/1962 survey of radiography room with 2 Co-60 sources exposed (NCC 1962) 

• 8/1/1962 survey of radiography room with 2 Co-60 sources exposed (NCC 1962) 

• 11/6/1962 inspected by the AEC (AEC 1962a) 

[5. The frequency of the radiographic examinations at GSI was driven by the rate at 

which products were produced. There is no reason to believe that this production rate 

would change due to the purchase of the Co-60 sources.] The purpose of the source 

change was to discontinue the use of radium, not change the testing program. Also, the date 

of the AEC inspection is less than six months after the Co-60 sources were purchased. This 

makes the inspection contemporaneous with the use of radium sources since they would have 

been used at least until the Co-60 sources were purchased. Therefore, [6. the frequency of 

radiographic examinations discussed in the 11/6/1962 AEC inspection is considered the 

same frequency that the radium sources were used.]

The AEC inspection, conducted on 11/6/1962 indicated that [7a. approximately 10 

radiographic examinations were conducted per work shift and these examinations 

varied from one minute to 70 minutes in duration (AEC 1962a, pg 3). Another report 

indicated a maximum of 30% of each shift is used for actual examinations. That report 

also indicated exams ranged from 1 or 2 minutes up to 1.5 hours (AEC 1962 pg 12). The 

examination durations in the two reports are reasonable consistent.] The first report 

gives no indication of the total duration per shift while the second report indicates 30% of an 

8 hour shift (144 minutes). [7b. Therefore, it will be assumed that Ra-226 and Co-60 

radiography consisted of 10 shots per shift for a total duration of 144 minutes]. 

[8. An estimate of the radiographer dose during Ra-226 radiography can then be made 

by assuming 1.33 mR/shot (from placing and retrieving the source)] times 10 shots per 

shift times 406.25 shifts per year for an annual dose of 5411.25 mR. Added to that is the 

boundary dose rate of 0.89 mR/hr times 144 minutes per shift times 406.25 shifts per year for 

an annual dose of 868 mR. This results in a total annual dose of 6279 mR.

[9. That estimate is very dependent on time and distance associated with placing and 

retrieving the source. Those parameters are not well known.] While the recollection of 

the former radiographer is likely to be accurate for his own experience, it is not necessary 

accurate for others. Therefore, an additional estimate using worst case time and distance from 

the worker’s recollection was calculated. Using the same technique as before but substituting 

4 feet and 15 seconds for placing and retrieving the source, [10. a new estimate of 9.40 R/yr 

can be calculated for placing and retrieving the sources]. In addition, [11. it was reported 

that the majority of radiography occurred in the radiography room of the number 6 

building]. An MCNP model was constructed of the room and used to estimate a dose rate of 

0.303 mR/hr in the

[Page 23 of 38]
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45

control room. The radiographer was reported to spend most of his time during the shot in this 

control room. The model was based on a [12. drawing from the AEC license application 

(figure 8).] Using the results of this model and the source utilization time of 144 minutes per 

shift, the annual dose received during the shots can be calculated to be 295 mR/yr. 

Combining that dose with the dose from placing and retrieving the source results in an annual 

dose estimate of 9.69 R/yr. 

[13. Also, while dosimetry data for this time frame could not be located (with the 

exception of a few examples), there were indications that a dosimetry program did exist. 

The application for an AEC license indicated that using this technique, no one had ever 

exceeded the annual limit applicable at the time and the average was always below 25% 

of the limit]. The exposure limit from 1952 through 1961 was 15 rem per year. After that, 

[14. the limit was changed to a lifetime limit not to exceed 3 rem per calendar quarter 

which equates to no more than 12 rem per year]. 

[15. A former radiographer provided a report summarizing his radiation dose while the 

radium sources were still in use. The record indicated that at GSI, he received 9.1 rem 

in 18 calendar quarters or 2.022 rem per year on average. An interview with the 

radiographer indicated he only performed radiography on a part time basis and 

estimated he did this between 40 to 90 shifts per year (SC&A 2011)]. Receiving 2.022 

rem in 90 shifts is equivalent to 0.0225 rem/shift. This would result in an estimate of 9.12 

rem per year to a full time radiographer. 

To account for the variation in these estimates, a triangular distribution will be used as the 

dose estimate for radium radiography. [16. The minimum values will be the 6.279 R/year]. 

The [17. likely value will be 9.69 R/yr] and the maximum will be the AEC limit (15 rem/yr 

or 12 rem/yr depending on the year). [18. It should be noted that this is consistent with the 

GSI statement in the AEC License application indicating the applicable limit has never 

been exceeded. It is also consistent with the dose received by the part time radiographer 

discussed above.]

Cobalt-60 Radiography 

By 1963 the use of radium for radiography at GSI had ended and the sources were replaced 

with two Co-60 sources. The Co-60 sources were purchased in 1962 and a survey was 

conducted of the number 6 building radiography room on 6/24/1962 and 8/1/1962. It is likely 

the Co-60 sources had begun being used soon after and the Ra-226 sources retired. However, 

since an exact date is unknown, this estimate uses the favorable assumption that the Ra-226 

sources continued to be used through the end of 1962. 

[19. It was reported that the majority of Co-60 radiography occurred in the 

radiography room of number 6 building. Some may have been done outside of that 

room but it appears to have been infrequent]. The surveys conducted on 6/24/1962 and 

8/1/1962 showed a maximum dose rate on the exterior of the radiography room of 1.2 mR/hr. 

The maximum dose rate in the control room was 1.15 mR/hr (NCC 1962). While the 

operators were reported to spend most of the time during the shot in the control room, it is 

also possible they left the building and [20. could have been in the 1.2 mR/hr area]. Since 

the difference is small, this estimate assumes the operators spend 100% of the time the 

sources were exposed, outside the room near the wall where the [21. reading was 1.2 
DWM_GSIappBBr1_critique-F.doc

46

mR/hr.] Multiplying this by 144 minutes of exposure per shift and 406.25 shifts per year 

gives an annual dose of 1170 mR. 

[Page 24 of 38]

Iridium-192 Radiography 

[22. An Ir-192 source was also reported to have been used on site. No Ir-192 source was 

ever added to GSI’s AEC license or requested to be added]. A former worker for a local 

company, [23. St. Louis Testing, reported that he was contracted at times to bring 

sources (including an Ir-192 source and a Co-60 source) on site to perform 

radiography]. He later reported that this did not occur before 1963 and that St. Louis Testing 

personnel would perform the operation without GSI personnel. He also reported a boundary 

would be set up and guarded by St. Louis Testing during the shot. [24. The boundary was 

setup at a distance that would result in an exposure rate of 2 mR/hr.] [25. Even if St. 

Louis Testing used a source full time and a GSI employee stood at the boundary full 

time, the annual gamma dose would be less than that of the layout man estimate. 

Therefore, dose estimate of these sources would not be the limiting estimate and thus 

will not be included in the GSI estimate]. 

MCKEEL	COMMENT	to	BB4.4	External	Dose	Estimate	for	Isotope	source	

Operations:

[1.	Radium-226	Radiography...	sources	were	500	mg	(500mCi)]	-- This	source	

intensity	figure	was	applicable	to	the	Ra-226	sources	when	they	were	first	

purchased	(date	unknown).	It	is	not	known	whether	any	leakage	occurred	or	

what	the	exact	1962	decay	level	had	become.	GSI	stated	the	Ra-226	sources	

were	rented,	but	not	who	the	vendor	was.	There	are	no	GSI	shot	records,	leak	

test	results	from	St.	Louis	Testing	Co.	(the	GSI	site	expert	team	asked	for	them	

from	Paul	Sinn),	or	sealed	source	maintenance	records	of	any	kind.

[2.	A	special	radiography	room	was	built	within	the	#6	building]	-- Allen	needs	

to	note	the	structure	was	built	in	1955 (two	eyewitnesses)	and	at	first	had	

walls	only	8	inches	thick	composed	of	perforated	8	inch	concrete	blocks.	A	GSI	

1957	master	engineering	drawing	clearly	showed	an	inner	“radiography	

room”	within	the	confines	of	Bldg.	6 (from	a	McKeel	white	paper).

[3.	walls	of	the	room	were	constructed	with	24”	thick	sand	filled	concrete	blocks]	

-- Allen	needs	to	cite	the	NRC	ML	report	number,	date	and	page	numbers	for	

this	statement.	As	stated	in	item	2,	two	eyewitnesses	stated	the	original	

concrete	block	walls	were	only	8	inches	thick.	Several	other	workers	(John	

Dutko,	deceased,	was	one	of	them)	thought	the	walls	were	only	8	inches	thick	

while	he	worked	at	GSI	as	a	radiographer	(1963-1966).	The	GSI	site	expert	

team	challenges	the	accuracy	of	the	24	inch	thick	inner	structure	Radiography	

room	walls in	the	Bldg.	6	radiography	room. The	Ra-226	and	Co-60	dose	

delivery	outside	would	be	higher	with	thinner	8	inch	walls	compared	to	

thicker	16	or	24	inch	thick	walls	shown	in	some	inner	Bldg.	6	structural	
DWM_GSIappBBr1_critique-F.doc

47

sketches.	Again,	these	are	not	“as-built”	certified blueprints.

[4.	A	boundary	was	reportedly	set	up	at	1.5	times	the	required	distance.	The	

required	distance	would	be	the	point	where	the	radiation	levels	fell	below	2	

mR/hr.]	-- Allen	needs	to	also	include	the	NRC	mandated	100	mR/hr	barrier.

[5.	The	frequency	of	the	radiographic	examinations	at	GSI	was	driven	by	the	

rate	at	which	products	were	produced.	There	is	no	reason	to	believe	that	this	

production	rate	would	change	due	to	the	purchase	of	the	Co-60	sources.]	-- It	is	

equally	true	there	is	no	reason	to	assume	the	production	rate	would	NOT	

change,	or	in	what	direction	according	to	current	contracts,	after	the	switch	

from	Ra-226	to	Co-60	NDT	sealed	sources	occurred in	1963.	Allen	is	guessing	

and	his	logic	is	flawed.	An	unchanging	production	rate is	an	invalid,

scientifically	indefensible	assumption.	An	unchanging	production	rate	across	

Ra-226	and	Co-60	source	eras	should	NOT	be	assumed.	What	is	required	is	

measured	data that	NIOSH	does	not	have. GSI	merited	an	83.14	SEC	all	along	

due	this	gross	deficiency of	area	or	individual	monitoring	or	process	or	source	

data. OCAS	Director	Elliott	in	2005	admitted	GSI	was	a	“unique	site.”

[6.	the	frequency	of	radiographic	examinations	discussed	in	the	11/6/1962	AEC	

inspection	is	considered	the	same	frequency	that	the radium	sources	were	

used.]	-- Since	all	GSI	log	books,	job	lists,	and	shot	lists	are	lost	or	destroyed,	

there	is	no	independent	GSI	data	corroboration	of	the	number	of	shots	the	AEC	

inspector	assessed	to	be	the	case	in	1962.	None	of	the	GSI	workers	the	GSI	site	

expert	team	interviewed	remembered	being	interviewed	by,	or	meeting,	AEC	

inspectors.	The	same	workers	deny	such	regular	AEC	inspections	took	place	

during	the	operational	period.	This	is	reinforced	because	no	such	records	are	

available	for	the	MCW	site	concerning	the	Betatron	contract	work	done	at	GSI	

in	Illinois.	This	analysis	also	applies	to	comments	on	items	7a	and	7b	below.

[7a.	approximately	10	radiographic	examinations	were	conducted	per	work	

shift	and	these	examinations	varied	from	one	minute	to	70	minutes	in	duration	

(AEC	1962a,	pg	3).	Another	report	indicated	a	maximum	of	30%	of	each	shift	is	

used	for	actual	examinations.	That	report	also	indicated	exams	ranged	from	1	

or	2	minutes	up	to	1.5	hours	(AEC	1962	pg	12)]	-- See	McKeel	comment	item	6.

[7b.	Therefore,	it	will	be	assumed	that	Ra-226	and	Co-60	radiography	consisted	

of	10	shots	per	shift	for	a	total	duration	of	144	minutes]	-- See	McKeel	comment	

to	item	6.

[8.	An	estimate	of	the	radiographer	dose	during	Ra-226	radiography	can	then	

be	made	by	assuming	1.33	mR/shot	(from	placing	and	retrieving	the	source)]	--

Where	is	the	1.33	mR/shot	value	derived	(cite	DCAS	or	SC&A	white	paper	

report,	AppBBr1	page	number,	reference	number,	author,	title,	SRDB	number,	

page(s) cited? The	detailed	complete	citation	is	needed.
DWM_GSIappBBr1_critique-F.doc

48

[9.	That	estimate	is	very	dependent	on	time	and	distance	associated	with	

placing	and	retrieving	the	source.	Those	parameters	are	not	well	known.]	--

These	terms	are	not	known	from	shot	records,	log	books,	etc., at	all because	all	

such	records	are	missing	or	destroyed	at	GSI.	The	testimony	about	the	use	of	

Ra-226	sources	by	GSI	radiographers	is	very	sketchy.	McKeel’s	view	is	the	

record	is	so	skimpy	as	to	be	totally	unreliable	for	assigning	doses	with	

suffcient	accuracy	in	a	plausible,	claimant favorable	way.	Allen	has	not	met	

this	standard.

[10.	a	new	estimate	of	9.40	R/yr	can	be	calculated	for	placing	and	retrieving	the	

sources]	--Allen	again	has	made	a	too	brief	statement	about	an	exceedingly	

important dose	assignment.	A	fuller detailed	citation	of	the	data	source	is	

required:	author,	report	number	and	title,	SRDB	number,	date,	and	pages	need	

to	be	stated	here.	“Can	be	calculated”	should	be	replaced	by	“was	calculated	as	

follows”	citing	the	detailed	reference.

[11.	it	was	reported	that the	majority	of	radiography	occurred	in	the	

radiography	room	of	the	number	6	building]	-- (a)	It	is	tedious	to	have	to	state	

that	once	again	Allen	has	ignored	the	affidavits	of	two	GSI	workers	(Dave	

Woodard	and	Danial	Churovich),	who	both	were	eye	witnesses	to	the	inner	

concrete	block	“radiography	room”	marked	on	the	GSI	1957	master	

engineering	drawing	that	the	GSI	site	expert	team	provided	to	the	TBD-6000	

WG	and	documented	in	McKeel	white	papers.	Both	GSI	workers	stated	the	

inner,	roofless	building	6	radiography	facility	was	constructed	in	the	year	

1955 and	had	8	inch	thick	concrete	block	walls	filled	with	“Miss.	River	sand.”

(b)	Allen	ignores	this	fact,	which	mandates	that	doses	from	two	(2)	GSI	

Radium-226	source	gamma	photon	external	doses	he calculated for	the	

covered	period	Oct.	1,	1952, through	some	time	in	1955, be	re-calculated	for	

shots	in	the	open	areas	anywhere	within	the	GSI	building	complex.	

(c)	The	GSI	expert	team	has	provided	the	TBD-6000	WG	photos	from	

the	GSI	company	magazine	showing	rows	of	railroad	trucks,	a	major	

component	manufactiured	and	examined	at	GSI	by	both	Ra-226	and	Co-60	

NDT	isotope	radiography, in	an	open	building	consistent	with	Bldg.	6.	

(d)	Neither	NIOSH	nor	SC&A	have	calculated	open	space	external	photon	doses	

for	10/1/52	through	1955	when	the	Bldg.	6	inner	block	building	was	built	at	

GSI.	

(d)	It	should	also	be	noted	that	SC&A	alone	calculated	Ra-226	photon	

exposures	for	radiographers	stationed	within	the	Bldg.	6	radiography	room	

after	1955	through	1962,	who	worked	on	NDT	jobs. SC&A	did	NIOSH’s	job.

(e)	Finally,	GSI	radiographer	(Leroy	Dell)	testimony	indicates	that	Ra226	and	Co-60	shots	done outside	of	the	Bldg.	6	radiography	room	were	often	

NOT	roped	off	and	were	often	NOT	monitored.	The	claimant	favorable	position	

would	involve	passerby	workers	being	in	close	proxity	to	the	open	Ra-226	

sources.

[12.	drawing	from	the	AEC	license	application	(figure	8).]	-- The	cited	document	
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49

“ML”	and/or	SRDB	numbers,	author,	title,	report	number,	year	and	pages	

needs	to	be	referenced.

[13.	Also,	while	dosimetry	data	for	this	time	frame	could	not	be	located	(with	the	

exception	of	a	few	examples),	there	were	indications	that	a	dosimetry	program	

did	exist.	The	application	for	an	AEC	license	indicated	that	using	this	technique,	

no	one	had	ever	exceeded	the	annual	limit	applicable	at	the	time	and	the	

average	was	always	below	25%	of	the	limit]	-- NIOSH	cites	non-specified	

“indications”	and	infers	“that	a	dosimetry	program	exists”	but	has	not	

provided	any	written	evidence	for	this	supposition.	Allen	needs	to	spell	out	

what	these	indications	are?	It	is	the	job	of	NIOSH	and	DOE	to	locate	through	

research,	and/or	otherwise	provide,	the	real	measured	monitoring	data	for	

each	AWE	and	DOE	site.	Allen	also	needs	to	note	that	GSI	radiographers	JEP	

and	Ron	Elliott	initially	provided their	personal	film	badge	reports	to	the	GSI	

site	expert	team,	who	in	turn	shared	these	data	with	NIOSH,	the	TBD-6000	WG	

and	the	Board.	This	voluntary	sharing	was not	reciprocated.	NIOSH	to	date	has	

witheld	the	Landauer	Dataset	#2084	1963-1973	to	itself	and	SC&A.	The	

complete	dataset	listing,	including	the	not	“M”	values, has	NOT	been	published	

by	NIOSH.	Allen	and	DCAS	need	to	acknowledge	the	original	data	sources	for	

information	they	use	in	TBDs.	In	this	case,	the	attribution	should	be	to	SINEW	

(McKeel	and	Ramspott),	members	of	the	GSI	expert	team.

[14.	the	limit	was	changed	to	a	lifetime	limit	not	to	exceed	3	rem	per	calendar	

quarter	which	equates	to	no	more	than	12	rem	per	year]	-- What	is	the	

authority	for	this	statement	and	where	is	the	change	officially	announced?

[15.	A	former	radiographer	provided	a	report	summarizing	his	radiation	dose	

while	the	radium	sources	were	still	in	use.	The	record	indicated	that	at	GSI,	he	

received	9.1	rem	in	18	calendar	quarters	or	2.022	rem	per	year	on	average.	An	

interview	with	the	radiographer	indicated	he	only	performed	radiography	on	a	

part	time	basis	and	estimated	he	did	this	between	40	to	90	shifts	per	year	(SC&A	

2011)]	-- Dan	McKeel	is	the	recognized	representative	(by	the	CDC/ATSDR	

Atlanta	GA FOIA	office)	for	film	badge	matters	for	the	radiographer	alluded	to	

(James	E.	Powers	or	JEP).	That	person	filed	a	PA	request	on	June	19,	2013	to	

obtain	his	complete	Landauer	GSI	#2084	film	badge	data	set.	To	date	

(7/15/14)	he	lacks	his	1966	Landauer	badge	data	(DCAS	sent	him		single	

page).	The	brief	report	alluded	to	was	NOT	generated	by	Landauer.	The	

alluded	to	film	badge	raw	data	has	NOT	been	located	by	NIOSH.

[16.	The	minimum	values	will	be	the	6.279	R/year]	-- What	data	supports	this	

lower	limit	value?	Allen	needs	to	specify	report	title	and	SRDB	number,	year	

published,	author(s)	and	pagination.	The	citation	should	be	included	in	the	

References.

[17.	likely	value	will	be	9.69	R/yr]	-- What	does	“likely”	mean?	What	criteria	

can	DOL	use	for	assigning	this	“likely	dose?”	McKeel	believes	this	will	be	
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50

difficult	or	impossble	in	many	cases.	Having	three	values	will	lead	to	

unfavorable	dose	underestimates	in	his opinion.	The	claimant	favorable	

position	would	be	to	assign	everyone	except	administrative	personnel	at	GSI	

the	upper	value	of	the	triangular distribution (12	or	15	REM/year).

•	What	data	supports	this	middle	limit	value	for	the	triangular	distribution?	

Allen	needs	to	specify	the	report	title	and	SRDB	number,	year	published,	

author(s)	and	pagination.	The	citation	should	be	included	in	the	References.

[18.	It	should	be	noted	that	this	is	consistent	with	the	GSI	statement	in	the	AEC	

License	application	indicating	the	applicable	limit	has	never	been	exceeded.	It	is	

also	consistent	with	the	dose	received	by	the	part	time	radiographer	discussed	

above.]	-- The	specific	citation	for	the	“GSI	statement	in	the	AEC	license	

application”	is	buried	within	1,016	pages	ofNRC	FOIA	201-0012	obtained	by	

Dan	McKeel.	References	to	particular	material	in	that	set	of	37	documents	in	

the	INDEX	NRC	provided,	and	that	McKeel	posted	on	the	DCAS	website.	need	to	

be	referenced	by	Mr.	Allen	by	“ML”	document	number,	date	and	page(s).

•	The	GSI	expert	team’s	strong	objections	to	accepting	this	statement	by	a	GSI	

official,	who	needed	to	persuade	the	AEC	to	grant	a	By-Products	material	

license,	should	not	be	accepted	in	the	complete	absence	of	any	corroborating	

hard	evidence.	Specifically,	there	are	no	other	film	badge	reports	than	the	

Landauer	GSI	#2084	dataset,	and	Powers-Elliott	personal	AEC/NCC/GSI data	

reports rendered	in	a	completely	different	format.	NIOSH	never	located	the	

raw	film	badge	data	from	a	second	badge	vendor and	believes	the	other	badge	

reports	came	from	GSI.	McKeel	FOIA’d	NCC	license	data	from	DOE	but	received	

no	responsive	documents.	In	fact,	DOE	was	unable	to	confirm	an	AEC	license	

for	NCC	existed	even	through	NRC	FOIA	2012-0012	contained	a	specific	AEC	

license	number	for	NCC.	The	FOIA	officer	could	not	confirm	NCC	existed	as	a	

corporate	entity.	I	mention	all	of	this	background	to	highlight	how	unscientific	

it	is	for	NIOSH	to	naively	accept	a	naked	statement	from	a	biased	GSI	official,	

who	gave	no	details	to	back	up	the	veracity	of	his	“never	exceeded	limits”	and	

“25%”	statements	(uncorroborated	claims).	NIOSH	has	rarely,	if	ever	to	Dan	

McKeel’s	knowledge, resorted	to	using	AEC	limits	to	determine	a	bounding	

photon	dose	at	any	other	EEOICPA	site.	The	GSI	letter	cited	did	not	state	

whether	the	reference	was	to	photons,	neutrons,	beta	or	alpha	or	to	all	four.	

The	Landauer	GSI	FB	dataset	#2084	included	only	photon dosimetry	data.		

Neutron	and	beta	and	alpha	doses	were	not	determined	for	any	GSI	worker	

1952	through	1973.

[19.	It	was	reported	that	the	majority	of	Co-60	radiography	occurred	in	the	

radiography	room	of	number	6	building.	Some	may	have	been	done	outside	of	

that	room	but	it	appears	to	have	been	infrequent]	-- Different	radiographers	

gave	varying	testimony	on	the	frequency	of	Co-60	NDT	shots	performed	

outside	the	Bldg.	6	radiography	room.	Mr.	Dell	told	the	GSI	site	expert	team

the	outside	Co-60	shots	he	knew	about	were	frequent (not	infrequent/rare)	

and,	more	importantly, from	a	radiation	exposure	point	of	view,	shots	were	

frequently	unattended.	The	radiographer	often	set	up	the	Co-60	shot	and	then	
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51

returned	to	one	of	the	Betatron	facilities	to	continue	doing	NDT	radiography

there.	The	GSI	expert	team	made	the	TBD-6000	WG	and	Mr.	Allen	aware	of	this	

information,	and	DCAS	and	SC&A	jointly	interviewed	Mr.	Dell	with	McKeel	as	a	

silent	non-participating	observer.

[20.	could	have	been	in	the	1.2	mR/hr	area]	-- Paul	Sinn	of	St.	Louis	Testing	

Company	testified	he	was	present	at	25	to	50	Ir-192	shots	his	company	was	

hired	to	perform	at	GSI.	He	testified	to	the	GSI	expert	team	that	NRC	required	a	

second,	more	stringent	and	constantly	guarded	safety	barrier where	the	

source	term	dose	was	100	mR/hr.	Allen	as	a	member	of	the	TBD-6000	WG	

received	this	vital	information	but	chose	to	omit	it	from	AppBBr1	(6.6.14).	It	is	

Mr.	Allen’s	job	to	know	and	use	this	type	of	information.

[21.	reading	was	1.2	mR/hr.]	-- Please	refer	to	item	20	comment.

[22.	An	Ir-192	source	was	also	reported	to	have	been	used	on	site.	No	Ir-192	

source	was	ever	added	to	GSI’s	AEC	license	or	requested	to	be	added]	-- This	

statement	is	patently	untrue.	Dan	McKeel	and	the	GSI	site	expert	team	

specifically	reported	to	the	TBD-6000	WG	the	wording	in	a	GSI	1972	AEC	

license	renewal. Specifically,	NRC	ML093480290	Page	2	of	2,	License	Number	

12-08271-01,	Amendment	No.	08	dated	3/15/72	reads	as	follows:	

“12.	The	licensee	is	authorized	to	receive,	possess,	and	use	

sealed sources	 of	 Iridium	 192 or	 Cobalt	 60	 where	 the	

radioactivity	specified	in	item	8	of	this	license	provided:	A.	

Such	 possession	 does	 not	 exceed	 the	 quantity	 per	 source	

specified	 in	 item	 8	 by	more	 than	20%	 for	 iridium	 192 or	

10%	 for	 Cobalt	 60;	 ...	 [B,	 C	 follow	 to	 end	 item	 12	 of	 13]).	

The	 complete	 first	 two	 pages	 of	 the	 NRC	 document	 is	

attached	 on PAGES 78-80 as	 MCKEEL	 EXHIBIT	 1.”	 (added	

emphasis)

•		Mr.	Allen	needs	to	retract	statement	22 and	modify	AppBBr1	accordingly.	

Again,	the	TBD-6000	WG	was	knew	about	this	information.

[23.	St.	Louis	Testing,	reported	that	he	was	contracted	at	times	to	bring	sources	

(including	an	Ir-192	source	and	a	Co-60	source)	on	site	to	perform	radiography]	

-- Paul	Sinn	testified	to	the	GSI	expert	team	in	2013	that	he	personally	was	

aware	of	25	to	50	NDT	jobs	that	St.	Louis	Testing	Co.	did	at	GSI	using	their	Ir192	source.	Sinn	stated	that	St.	Louis	Testing	Co.	performed	only	one	Cobalt60	10	Curie	NDT	job	outside	the	10	building	with	the	casting	mounted	on	a	

railroad	car.	This	job	required	Co-60	shots	for	8	days	to	cover	the	entire	

casting. GSI	men	participated.	The	TBD-6000	WG got	this	information.

[24.	The	boundary	was	setup	at	a	distance	that	would	result	in	an	exposure	rate	

of	2	mR/hr.]	-- Mr.	Sinn	testified	to	the	GSI	site	expert	team	that	NRC	required	
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52

an	inner	safety	boundary,	to	be	constantly	monitored	by	St.	Louis	Testing	Co.,	

at	the	100	mR/hr	boundary.	This	added	barrier	was	set	up	and	monitored	at	

all	St.	Louis	Testing	Co.	GSI	NDT	jobs.

[25.	Even	if	St.	Louis	Testing	used	a	source	full	time	and	a	GSI	employee	stood	at	

the	boundary	full	time,	the	annual	gamma	dose	would	be	less	than	that	of	the	

layout	man	estimate.	Therefore,	dose	estimate	of	these	sources	would	not	be the	

limiting	estimate	and	thus	will	not	be	included	in	the	GSI	estimate]	-- (a)	Again,	

Mr.	Allen	cannot	just	make	qualitative	declarations	in	order	to	dismiss	the

need	to	comply	with	OCAS-IG-003	and	to	bound	external	doses	for	all	

radiation	sources.	Only	after	quantitative	dose	estimates	have	been	finalized	

is	it	proper	to	make	statements	such	as	item	25; (b)	GSI	personnel	were	used	

to	monitor	the	2	mR/hr	but	not	the	100	mR/hr	source	safety	boundary	for	St.	

Louis	Testing	Co.	Ir-192	NDT	jobs;	and	(c)	exactly	what	comparative	external	

photon	doses	will	be	assigned	to	personnel	for	St.	Louis	Testing	Co.	GSI	NDT	Ir192	shots	compared	to	the	same	type	of	doses	that	GSI	layout	men	would	be	

exposed	to? To	my	knowledge,	neither	NIOSH	nor	SC&A	have	bounded	or	been	

directed	to	bound	any Ir-192	source	external	doses	at	GSI.	This	would	include	

shots	delivered	by	the	St.	Louis	Testing	Co.	and	GSI	owned	Ir-192	gamma	NDT	

sources.	GSI	badged	radiographers	also	used	the	American	Steel	Ir-192	source	

to	perform	NDT	inspections of	flaws	in	GSI	steel	products	on	an	“overflow”	

basis. GSI	Betatron	uranium	radiographer	Ed	Brawley	was	one	who	gave	this	

American	Steel-GSI	testimony.

BB.4.5 External Dose Estimate for portable x-ray machines 

[1. The existence of a portable 250 kvp x-ray machine was reported at GSI. It was also 

reported that more than one of these machines had existed]. As with other sources of 

radiation, the purpose of these was to produce a radiograph of metal for quality control 

purposes. In order to produce a clear radiograph, the film cannot be exposed to stray sources 

of radiation so these machines would not have been used in the same vicinity at the same 

time. Nor would they have been used near [2. Others] sources of radiation. 

[3. Details about the use of these machines are limited. A few former radiographers 

recall using the machines but they were reported to be used rarely]. The x-ray beam is 

not of sufficient energy to activate nuclides in the material being x-rayed, so no source of 

exposure from freshly x-rayed material would exist. The maximum x-ray energy of a 250 kvp 

x-ray machine would be 0.25 MeV. This x-ray beam would have considerably less 

penetrating power than the betatron or the Co-60 sources. As such, it would only be used to 

x-ray relatively thin metal and [4. such an x-ray would be short in duration.] With the 

reported limited use and short durations when it was used, [5. the annual dose to a 

worker from using this machine would be less than that estimated for the Ra-226 

sources or working as a layout man. Therefore, dose estimate of this machine would not 

be the limiting estimate and thus will not be included in the GSI estimate].

MCKEEL	COMMENT	to	BB4.5	External	Dose	Estimate	for	portable	x-ray	

machines:
DWM_GSIappBBr1_critique-F.doc

53

[1.	The	existence	of	a	portable	250	kvp x-ray	machine	was	reported	at	GSI.	It	was	

also	reported	that	more	than	one	of	these	machines	had	existed]	-- Yes,	the	GSA	

1974	auction	list	for	GSI	after	plant	operations	ceased	listed	three	(3)	GSI	

conventional	x-ray	units	for	sale.	The	specific	model	numbers,	manufacturers,	

and	nominal	output	voltages	were	supplied	to	the	TBD-6000	WG	by	the	GSI	

site	expert	team	in	oral	testimony	and	McKeel	white	papers.	NRC	FOIA	2010-

0012	reports	also	documented	that	two	of	these	conventional	voltage	x-ray	

units	were	industrial	x-ray	units	and	one	was	a	medical	x-ray	unit.	Mr.	Allen	

should	have	included	all	this	detail	in	AppBBr1	since	the	details	were	not	

available	when	AppBBr0	was	issued	(June	25,	2007).

[2.	Others]	-- The	word	“Others	“	should	be	changed	to	“other.”

[3.	Details	about	the	use	of	these	machines	are	limited.	A	few	former	

radiographers	recall	using	the	machines	but	they	were	reported	to	be	used	

rarely]	-- The	scant	worker	testiimony	does	not	provide	a	clear	and	persuasive	

picture	of	useage	of	the	two	250	Kvp	NDT	x-ray	machines.	All	GSI	shot	records,	

job	records,	and	exposure	log	books	were	lost	or	destroyed.	Mr.	Allen	resorts	

to	cherry	picking.	I	believe	“rarely”	is	his	term.	The	worker	testimony	source	

he	is	referrring	to	needs	to	be	cited	by	transcript	date	and	page	number.	The	

frequent	use	by	Allen	of	unsupported,	not	referenced,	worker	statements	is	a	

major	scientific	weakness	of	AppBBr1.

[4.	such	an	x-ray	would	be	short	in	duration.] -- Qualitative	and	vague	terms	

such	as	“short”	are	meaningless	in	a	scientific	DR	guidance	document.	

Quantitative	data	and	operating	parameters	such	as	the	delivered	dose	rate

and	exposure	time	(in	minutes,	seconds)	are	needed. What	was	the	

millamperage	of	the	x-ray	machines	duing	x-ray	delivery?

[5.	the	annual	dose	to	a	worker	from	using	this	machine	would	be	less	than	that	

estimated	for	the	Ra-226	sources	or	working	as	a	layout	man.	Therefore,	dose	

estimate	of	this	machine	would	not	be	the	limiting	estimate	and	thus	will	not	be	

included	in	the	GSI	estimate]	-- The	first	sentence	is	pure	supposition.	

Allen/NIOSH	have	no	specific	information	on	frequency	of	use,	building

locations,	or	job	types	(what	castings	were	examined)	the	250	Kvp	industrial	

x-ray	units	were	used	for	at	GSI.	OCAS-IG-003	mandates	the	doses	from	both	

250	Kvp	x-ray	units	be	calculated.	Allen/NIOSH	need	to	provide	these	data.

BB.4.6	External	Dose	Estimate	for	Administrative	Personnel.	

[1. The dose estimate for administrative personnel is based on the reported practice of 

performing radiography in the main buildings outside of the #6 building radiography 

room. It is not clear how frequently this occurred.] It is also unclear if the reported 

practice of making a boundary at the point 1.5 times the required distance was always done. 

Therefore, this [2. estimate assumes the boundary was set at the required distance (2 
DWM_GSIappBBr1_critique-F.doc

54

mR/hr)]. It was also reported that the boundary was not always respected. People would at 

times cross the boundary and walk through the area if the boundary was unattended. 

As indicated previously, the sources are estimated to be in use an average of 144 minutes per 

8 hour shift. As a favorable assumption, it is assumed that every administrative person 

walked through the area twice (one round trip) every shift. The Ra-226 sources would 

produce a gamma dose rate of 4440 mR/hr at one foot. [3. A distance of 47.1 feet would be 

required to reduce the dose rate to 2 mR/hr.] It should be noted that the presence of 

castings and other materials in the area would likely reduce this distance in one or more 

directions.

[Page	25 of	38]

However, assuming no shielding is favorable for this calculation. Since the purpose of 

traveling through the area would presumably be to take a shortcut through the restricted area, 

it is assumed that the person could have traveled through the area at any distance from the 

source within the restricted boundary. Therefore, the dose for traveling through the area was 

calculated assuming the path took the person within 1 foot of the source (see Attachment A). 

The same calculation was performed assuming the person came within 2 feet, 3 feet, etc. of 

the source until all possibilities were calculated (in 1 foot increments). The average of these 

doses was calculated, multiplied by 2 trips per shift and then multiplied by 406.25 shifts per 

year to arrive at an annual dose of 84 mR. 

[4. It is also possible an administrative person stood at the boundary during the 

radiography.] Since this estimate is intended for people that did not spend their entire work 

day in the production areas, assuming 100% occupancy would be unrealistic. A favorable 

estimate of 25% is therefore assumed. This is considered favorable because it does not imply 

they only spend 25% of their time in the production area, it only implies they spend 25% of 

their time next to a radiography boundary. The remaining time could have been elsewhere in 

the production area or outside of the production area in their normal work area. Since the 

sources were exposed an average of 144 minutes per shift and the dose rate at the boundary 

was 2 mR/hr, the person could have received 487.5 mR per year during the 406.25 shifts per 

year. Combining this with the 84 mR received traveling through the area results in a dose 

estimate of 571.5 mR per year.

MCKEEL	COMMENT	to	BB4.6 External	Dose	Estimate	for	Administrative	

Personnel:

[1.	The	dose	estimate	for	administrative	personnel	is	based	on	the	reported	

practice	of	performing	radiography	in	the	main	buildings	outside	of	the	#6	

building	radiography	room.	It	is	not	clear	how	frequently	this	occurred.]	-- At	

least	three	different	GSI	radiographers	testified	about	this	point,	giving	

somewhat	different	accounts	of	the	facts.	Uncontested	(but	not	acknowledged	

yet	by	NIOSH)	is	the	fact	that	all	NDT	examinations	using	the	Ra-226	twin	

sources	(nominal 500	mCi,	decayed	values	not	known)	performed	at	GSI	prior	

to	sometime	during	1955,	when	the	inner	Bldg.	6	radiography	structure	was	

constructed),	were	done	in	the	open	6	through	10	plant	buildings	among	many	
DWM_GSIappBBr1_critique-F.doc

55

workers.	The	walls	of	the	structure	were built	of	a	single	layer	of	concrete	

sand-filled	blocks	that	two	eyewitness	observers	noted	to	be	only	8	inches	

thick.	One	radiographyer (Leroy	Dell)	stated	that	unmonitored	Ra-226	and	

Co-60	NDT	work	was	often	done	outside	the	Bldg.	6	roofless	radiography	

structure.	More	exact	details	are	lacking	as	Allen	states.

[2.	estimate	assumes	the	boundary	was	set	at	the	required	distance	(2	mR/hr)]	-

- There	was	a	more	rigorously	monitored,	NRC	mandated	safety	barrier	

marked	at	the	100	mR/hr	boundary	of	NDT	shots	(Paul	Sinn	St.	Louis	Testing	

Co.	testimony)	for	25	to	50	Ir-192	shots	he	supervised	at	GSI.	Allen	omits	

mention of	this	inner	higher	dose	safety	barrier or	its	ramifications.

[3.	A	distance	of	47.1	feet	would	be	required	to	reduce	the	dose	rate	to	2	mR/hr.]	

-- Observation:	This would	create	a	94.2	foot	diameter	safe	circle,	a	huge	area	

in	the	crowded	GSI	open-space	buildings 6	through	10.	The	diameter	of	the	

“safe	zone”	circle almost	guarantees frequent	incursions	would	occur.

[4.	It	is	also	possible	an	administrative	person	stood	at	the	boundary	during	the	

radiography.]	-- Many	scenarios	can	be	imagined.	Facts	are	lacking.	What	is	the	

point	of	adding	this	particular	statement?	Mr.	Allen	should	expand	the	text	to	

clarify	the	point	he	is	making.

BB.4.7 External Dose Estimate Summary 

The limiting external dose estimates depend on the worker category as well as the year in 

which they worked and the organ of interest for dose reconstruction. The results of the 

external dose estimates are provided below.

Administrative Workers 

This dose estimate is to be assigned for all years of AEC operations (October 1952 through 

June 1966). The years 1952 and 1966 are prorated for the partial year of operations. Partial 

years of employment within this time period should be prorated for each case. The dose 

should be assigned as 30 to 250 keV photons as a constant distribution. This estimate is 

assigned to Administrative Workers which are defined as anyone normally working in an 

office environment not routinely entering the	production areas. [1. All other employees will 

be assigned the dose estimate for Operators].

For Operators, the bounding estimate from the estimates derived above is used. Tables 8 and 

9 provide those estimates. [2. The bounding estimate in the early years at GSI is the dose 

estimate to the Ra-226 radiographers.] [3. After 1962, the bounding estimate is the 
DWM_GSIappBBr1_critique-F.doc

56

layout man dose estimate for most cases]. [4. In the case of the skin to the hands or 

forearms, the betatron operator dose estimate is limiting]. This is due to the much larger 

beta dose estimate for handling uranium. For a case of multiple cancers, if one or more but 

not all of the cancers include the skin of the hands or forearms, the dose estimate should be 

from only one of the tables below. That is, it should not be assumed that the skin received the 

betatron

[Page	26 of	38]

operator dose while the other organs received the layout man dose. Both tables should be 

used to estimate the dose to each organ and the more favorable overall estimate used.

MCKEEL	COMMENT	on	Table	8:	The	data	presented	in	this	Table	is	

fundamentally	incomplete	and	flawed.	“Operator”	refers	to	an	NDT	source	

term	radiographer.	All	radiographers	at	GSI	during	1952	through	1962	also	

were	operators	of	the	24	Mev	A-C	“Old”	Betatron	that	was	in	use	from	1952	

through	1973	when	the	plant	ceased	castings	operations.	Approximately	15%	

of	the	Betatron	beam	consisted	of	neutrons	generated	from	the	internal	

platinum	target.	Betatrons,	as	basically	electron	particle	accelerators,	also	

released	stray	electrons.	Some	clinical	Betatrons	had	two	output	tubes	that	

were	fitted	to	generate	either	electrons	(no	internal	target)	or	photons	(xrays)	and	neutrons	(target	inserted). Table	8	incorrectly	ignores	this	fact.	Our	

previously	cited	evidence	was	the	St.	John’s	hospital	(St.	Louis,	MO)	Betatron	

data	in	Scheutz	2007	and	data	from	three	similar	betatrons	in	the	NYO-4699	

(Suppl.	1)	paper	that	McKeel	introduced	to	the	TBD-6000	WG.	NIOSH	(Jim	

Neton	was	the	spokesperson)	rejected	using	this	reference	source	on	grounds	

that	McKeel	vigorously	rebutted	as	not	being	valid.	For	example,	Dr.	Neton	

claimed	the	diagrams	of	betatron	facilities	in	NYO-4699	(Suppl.	1)	were	too	

simplistic.	McKeel	pointed	out	the	drawings	were	as	detailed	as	the	Old	and	
DWM_GSIappBBr1_critique-F.doc

57

New	Betatron building	diagrams	(Figures	1	through	5)	in	this	paper.	McKeel’s	

view	is	the	NYO-4699	Betatron	building	diagrams	were	equally	informative.

The	co-petitioner’s	perception is	that	NIOSH	had	been	upstaged	once	again	in	

gaining	key	GSI-related	information,	and was	resistant	to	admitting	this	had	

occurred.	NIOSH’s	negative	response	to	the	two	NYO-4699	papers	was	not	

open	and	transparent	“best	practice”	science,	where	new	information	is	

respected	and	valued.	Note	that	NYO-4699(Suppl.	1)1957,	the	main	extant	

measured	Betatron	photon,	neutron	and	operator	film	badge	data, is	not	among	

the	included	NIOSH	references	for	either	AppBBr0	(2007)	or	AppBBr1	(2014).

GSI	radiographers	also	operated	the	GSI	Iridium-192	(sworn	GSI	worker	

affidavit	testimony)	gamma	source	(which	is	noted	in	the	GSI	license	that	

McKeel	first	obtained	and	shared	with	the	TBD-6000	WG	under	NRC	FOIA	

2010-0012)	and	two	250	Kvp	industrial	portable	x-ray	machines.	Allen’s	

paper	does	not	properly	attribute	this	important	contribution	made	by	the	GSI	

petitioners regarding	the	discovery	and	revelation	of	these	facts.

MCKEEL	COMMENT	to	Table	9: Claimants	should	be	credited	with	the	highest	

bounding	doses	for	photons,	beta	and	neutrons.	There	was	no	exclusive,	fulltime	job	classification	at	GSI	as	“layout	man.”	Radiographers	took	turns	as	

operators,	assistant	operators	and	layout	men.	Also	there	were	twice	as	many	

Betatron	operations	and	operators	during	1963-1966	at	GSI	when	two	A-C	24-

25	Mev	Betatrons	were	operating.	It	will	not	be	possible	for	DOL	to identify	a	

job	category	of	layout	man	at	General	Steel	Industries.	Dr.	Anigstein	of	SC&A	

adopted	this	new	term	“layout	man”	that	was	not	used	by	NIOSH	in	AppBB	Rev	

0	(June	2007).

Dan	McKeel	suggested	many	times	that	Appendix	BB	Rev	1	should	contain	a	
DWM_GSIappBBr1_critique-F.doc

58

detailed	listing	of	the	changes	between	Rev	0	(2007)	and	Rev	1	(2014).	I	note	

this	entirely	reasonable	suggestion	continues	to	be	ignored in	AppBBr1.

[Page 27 of 38]

Except for triangular distributions described in Table 8, all doses should be assigned as a 

constant distribution. Gamma doses should be assigned as 30 to 250 keV photons. Neutron 

doses should be assigned as 100 keV to 2 MeV neutrons and beta doses should be assigned as 

>15 keV electrons. 

MCKEEL COMMENT TO BB. 4.7	External	Dose	Estimate	Summary:

[1.	All	other	employees	will	be	assigned	the	dose	estimate	for	Operators]	-- My	

criticism	of	this	assignment	is	that	1963-1966	Betatron	Operator	external	

photon	doses	were	incorrectly	lowered	by	NIOSH	based	on	new	MCNP	

computer	code	modeling.	Dosimetry	values	obtained	in	2012	compared	to	

2008	were ~10-fold lower.	This	was	due	to	the	introduction	of	Landauer-GSI	

radiographer	film	badges	for	89	individuals	during	the	AEC	operational	

period	and	for	19	more	individuals	during	the	GSI	residual	contamination	

period.	Betatron	doses	were	somehow	“normalized”	to	film	badges	by	Allen	

and	DCAS/NIOSH	in	2012.	Then,	on	December	19,	2013,	Jim	Neton	issued	his	

Yoder-Hinnefeld	memo	in	which	NIOSH	declared	it	would	not	use	GSILandauer	FB	data	and	would	use	instead	an	(unspecified)	SC&A	method	that	

did	not	rely	on	film	badges.	Refer	to	Pages	13 to	15. The	specific	SC&A	

substitute	method	that	does	not	rely	on	FB	data	needs	to	be	cited	by	Allen.

[2.	The	bounding	estimate	in	the	early	years	at	GSI	is	the	dose	estimate	to	the	

Ra-226	radiographers.]	-- Allen	needs	to	show	the	actual	dosimetry	values	and	

pedigreed	data	that	support	this	statement.	The	2012-13	triangular	

distribution	dosimetry	values	for	Ra-226	Operators	overlaps	the	early	2008	

Betatron	Operator	photon	values	SC&A	made	before	the	introduction	of	

Landauer	FBs that	NIOSH	(Jim	Neton)	announced	on	December	19,	2013,	to	

the	TBD-6000	WG	it	would	no	longer	be	using. AppBBR1	needs	to	respect	and	

conform	with	this	NIOSH	memo,	as	unusual	a	precedent	as	it	espouses.

[3.	After	1962,	the	bounding	estimate	is	the	layout	man	dose	estimate	for	most	

cases]	-- Allen	needs	to	show	and	compare	the	2008	and	2012	data	on	the	

Betatron	operators	with	similar	data	for	2008	and	2012	layout/other	workers	

(from	AppBBr0).	Allen’s	presentation	of	these	quantitative	data	are	required	

before	statement	3.	can	be	accepted	as	being	scientifically	valid. What	does	

“most”	signify:	which	workers	other	than	administrative	are	included?

[4.	In	the	case	of	the	skin	to	the	hands	or	forearms,	the	betatron	operator	dose	

estimate	is	limiting]	-- Again,	what	values	are	being	compared,	Betatron	

Operators	to	whom,	Layout	men? This	statement	requires	quantitative	data	

and	a	clearer	explanation	of	what	is	being	compared	to	what.
DWM_GSIappBBr1_critique-F.doc

59

BB.5 Occupational Internal Dose 

The primary source of internal dose at GSI is handling uranium metal. No data was found 

related to occupational internal dose during AEC work at GSI. In addition, no records of air 

monitoring were found in the site research database. Since no intentional cutting, machining, 

or abrading of uranium was involved, [1. there was a low potential for producing elevated 

air concentrations of uranium]. [2. Another source of potential internal dose is the 

grinding of steel castings soon after being x-rayed in the betatron.] [3. The betatron 

photons are of sufficient energy to interact with materials and cause the creation of 

radionuclides]. 

MCKEEL	COMMENT	to	BB.5	Occupational	Internal	Dose:

[1.	there	was	a	low	potential	for	producing	elevated	air	concentrations of	

uranium] - This	statement	is	not	necessarily	true.	Adley	1952	at	the	Hanford	

melt	plant,	showed	higher	airborne	uranium	levels	in	three	types	of	Ur	-238	

handlers:	the	crew	that	unloaded	railroad	cars,	sweepers,	and	fork	lift

operators	(the	exhausts kicked	up	dust).	There	were	similar	jobs	at	GSI.	

McKeel	argued	the	Adley	1952	data,	that	is	a	part	of	TBD-6000	Rev	1	(June	

2011), should	have	been	considered	for	use	as	surrogate	uranium	intake	data	

at	GSI.

[2.	Another	source	of	potential	internal	dose	is	the	grinding	of	steel	castings	

soon	after	being	x-rayed	in	the	betatron.]	-- To	grinding	as	a	source	of	internal	

dose	from	machining	steel, should	be	added	dose	to	welders,	burners	and	

chippers.	These	jobs involved direct	air	intakes	and	all	also	released	large	

amounts	of	uranium	metal	fumes	and	particulates	into	the	air as	they	worked.	

Allen	needs	to	allow	for	these	types	of	jobs	that	were	represented	at	all	steel	

plants.

[3.	The	betatron	photons	are	of	sufficient	energy	to	interact	with	materials	and	

cause the	creation	of	radionuclides] -- Allen	ought	to	employ	the	most	exact	

scientific	terminology.	The	process	he	is	describing	that	can	“cause	the	

creation	of	radionuclides”	is	called	either	photon	or	neutron	activation and	

those terms should	be	used	to	differentiate	activation	from	nuclear	fission	

which	is	caused	by	24-25	Mev	betatrons	in	materials	such	as	uranium	and	

thorium.	Doses	assigned	should	be	based	on	the	full	range	of	radionuclides	

released	by	elemental	activation,	and	the	resulting	full	range	of	half-lives	and	

degree	of	radioactivity	induced	(specific	radioactivity)	should	be	used	in dose

calculations.

BB.5.1 Intakes from handling uranium metal 

Unlike many Atomic Weapons Employers (AWE) the AEC contracted work at GSI did not 

involve forming or shaping of uranium metal through processes such as rolling, machining, 

cutting, or straightening. The work at GSI consisted solely of taking x-rays of uranium metal 
DWM_GSIappBBr1_critique-F.doc

60

that were used to evaluate the integrity of the cast uranium metal manufactured at 

Mallinckrodt Chemical Works. Thus, the only potential for generation of airborne uranium at 

GSI would be from the movement of the metal into position for the examination. 

No air samples were found at GSI so data from the movement of uranium metal at other sites 

was compiled. Samples that may have been interfered with by other operations in the vicinity 

or associated with the movement of heated uranium metal were avoided since they would not 

be representative. 

Twenty-five samples from three different sites were found to be represent the airborne 

activity associated with the movement of cold (i.e., unheated) uranium metal. The samples 

represent several shapes and sizes of metal varying from one inch diameter by eight inch long 

slugs weighing a little over 4 pounds to 18 inch diameter by 18 inch long dingots weighing 

over 3000 pounds. An analysis of the airborne caused by moving these different forms found 

that the size and shape did not significantly affect the airborne concentration created by 

moving the metal (Attachment B). 

The data reasonably fit a lognormal distribution with a geometric mean of 17.5 dpm/m3 and a 

geometric standard deviation of 2.29. This distribution has a 95th percentile of 68.7 dpm/m3. 

The 95th percentile will be used in this estimate and applied as a constant. 

MCKEEL	COMMENT	to	BB.5.1	Intakes	From	Handling	Uranium	Metals: The	GSI	

expert	team	contested	the	use	of	uranium	slug	facilities	as	surrogate	data	at	

GSI,	which	did	not	use	this	form	of	the	metal.	The	GSI	expert	team	also	stated	

that	higher	uranium	airborne	intakes	as	documented	in	the	Adley 1952	

Hanford	melt	facility	report	would	be	more	claimant	favorable	surrogate	

uranium	handling	intake	data.	In	particular,	the	high	doses	documented	for	

crew	members	that	unloaded	U-238	from	railroad	cars	were	exposed	to	

particularly	high	levels	of airborne	uranium	dust.	Shift	hours	needed	to	be	

curtailed	at	Hanford	due	to	the	high	Ur	dust	levels	in	this	worker	subset.	

Forklift	operators	and	sweepers	also	were	exposed	to	high	Ur	dust	levels	at	

Hanford.	NIOSH	completely	ignored	the	complete	“uranium	transport	

pathway”	at	GSI	that	extended	from	the	rail	and	truck	unload	areas,	through	

the	loading	dock	and	weighing	stations,	then	along	the foundry	through	

multiple	buildings (5	through	10), before	the	uranium	metal	entered	the Old	

and	New	Betatron	facilities.	Uranium-238	airborne	doses	needed	to	be	

calculated	all	along	these	routes.	Also,	intakes	for	crane	operators	and	chain	

men	and	workers	who	cleaned	the	transport	cars	were	exposed	to	high	levels	

of	uranium	dust.	These	latter	Ur-238	intakes	were	not	calculated	by	NIOSH	or	

SC&A	as they	should	have	been.	All	source	term	exposures	need	to	be	

bounded,	and	these	were	not (OCAS-IG-003).

BB.5.2 Intakes from Fission Products 

Intakes of fission products must also be considered. Because there are many different 

isotopes produced as fission products, it makes it difficult to estimate internal dose from this 

process. Internal dose from uranium is caused by a low dose-rate delivered over years. Many 
DWM_GSIappBBr1_critique-F.doc

61

fission products on the other hand have a relatively short half-life so they do not deliver a 

dose for a long period of time. 

[Page 28 of 38]

An analysis conducted for revision 0 of this document determined that increasing the 

uranium airborne activity by 1% would be a favorable method of accounting for uranium 

fission and activation products. An independent review of this assessment agreed with 

NIOSH’s conclusion (SC&A 2008). Therefore, this revision will increase the uranium 

airborne activity by 1% in all calculations. 

MCKEEL	COMMENT	to	BB.5.2	Intakes	from	Fission	Products: Fission	and	

elemental	activation	are	two	different	processes.	In	fission,	heavy	elements	

such	as	uranium	and	thorium	and	plutonium	are	split	into	smaller	radioactive	

molecules called	daughter	products.	Allen	does	not	identify	the	specific	fission	

daughter	products	that	result	from	24-25	Mev	A-C	Betatron	x-irradiation,	

their	specific	activity	or	half-lives.	The	GSI	expert	team	provided	multiple	

relevant	literature references on	this	topic	to	the	TBD-6000	WG	and	cited	

them	in	McKeel	white	papers.

BB.5.3 Intakes from Activation products in Steel 

The purpose of x-raying steel castings was to detect internal flaws. Once found, they could be 

ground out and repaired. This implied the steel could be ground out soon after the x-ray while 

it is still radioactive, which would cause radioactive dust to be inhaled by the person grinding 

the casing. To estimate this intake pathway the layout man’s work scenario was utilized. It 

was assumed that someone was grinding on the freshly x-rayed casting the entire time and 

that the airborne activity produced during the grinding was 4 mg/m3. The 4 mg/m3 was 

derived from Table 7.5 of TBD-6000 which lists uranium airborne concentrations from 

uranium machining operations. Of the three grinding operations, centerless grinding had the 

highest results of 4000 to 5000 dpm/m3. This equates to a mass concentration 3.571 mg/ m3 

to 4.286 mg/ m3. 

The steel was assumed to be x-rayed with the betatron for 30 continuous hours prior to the 

layout man working on the casting. MCNP was used to determine the production rate of 

radionuclides in HY-80 steel and the specific activity of each radionuclide in the steel was 

determined. The activity was allowed to decay after the shot. It was assumed 4 mg/m3 of 

steel was always in the air from the casting and inhaled. This intake resulted in an annual 

internal dose less than one mrem for all organs. Therefore, no internal dose will be assigned 

from the inhalation of steel.

MCKEEL	COMMENT	to	BB.5.3	Intakes	from	Activation	products	in	Steel:

Activation	implies	displacement	of	one	or	more	orbital	electrons	or	other	

atomic particles,	thus	creating	a	host	of	new	“daughter”	radionuclides.	The	GSI	

expert	team	provided	the	TBD-6000	WG	several	related	literature	references	

by	Ziemer	and	Guo	(2004)	and	by	Kutemperoor	(1974).	Tables	in	McKeel	

white	papers	illustrated	the	important	fact	that	the	half	lives	of	multiple	

activation	daughter	products	of	steel	and	uranium	exceed	2	hours,	the	
DWM_GSIappBBr1_critique-F.doc

62

arbitrary	limit	set	by	NIOSH:	Eu	151	13.4	yr,	Eu	153	8.5	yr,	Co	59	5.27	yr.

and	Cs	133	2.65	yr	=	examples	of	this	principle	(McKeel	white	paper,	p.	20).

BB.5.4 Summary of Intakes of Radioactive Material 

Based on worker input, x-ray shots of uranium took 60 minutes each with 15 minutes 

between them. Furthermore, it was reported that 4 shots were taken on each piece of uranium. 

This implies the uranium was being moved only about 5% of the time the uranium was in the 

building (15 minutes out of 300 minutes). Since the uranium had to be properly positioned in 

the betatron building and not just moved, it may be reasonable to think that the manipulation 

of the uranium in the betatron building took more time than moving the same uranium to and 

from the building. [1. That would imply the time involved in moving uranium around the 

site would be less than 5% of the time it was in the betatron building]. 

However, there are several possibilities that could change that assumption. First, it is possible 

the handling inside the betatron building was more efficient than outside even if inside work 

involved proper placement and not just movement. Second, it is possible the uranium was 

moved from conveyance to conveyance within the site (fork truck, rail car, crane, etc.) thus 

representing multiple episodes of handling rather than once in each direction. It should 

however be noted that it is unlikely this occurred in one area. [2. More likely, the uranium 

would be moved some distance with each conveyance before being transferred to 

another conveyance and airborne activity would thus not accumulate in a single area]. 

Lastly, it possible that [3. while the uranium is being moved on a conveyance, additional 

airborne activity could be produced by vibrations. Again however, this would not occur 

in a single area but rather all along the path].

[Page 29 of 38]

[4. With these uncertainties in mind, this estimate will assume workers are exposed to 

uranium airborne contamination as if the uranium were handled 100% of the uranium 

contract time.] The uranium contract times vary by year as described in Table 2. The 

airborne concentration is assumed to be the 95th percentile of the uranium handling airborne 

distribution discussed in section BB.5.1. That value was increased by 1% to account for 

fission product activity (section BB.5.2). The annual intake was divided by 365 days per year 

to derive an intake rate per calendar day. The intake values are presented in Table 10. 

In between uranium work episodes, it is still possible to create uranium airborne 

contamination by resuspending any uranium surface contamination left behind by the 

uranium handling. Intakes from this scenario were calculated by first estimating the surface 

contamination by assuming the uranium airborne was deposited at a rate of 0.00075 m/s for 

30 days. [5. A resuspension factor of 1E-5 m-1 was then used] to calculate the airborne 

concentration due to resuspension. This concentration was assumed to be inhaled 

100% of the time during the operational period. The value was converted to dpm per calendar 

day and is presented in Table 10. 

Intakes due to ingesting uranium contamination were also calculated. [6. The ingestion 

intake was calculated using OCAS-TIB-009] and the 95th percentile of the uranium 

handling airborne distribution increased to account for fission products. These values are 
DWM_GSIappBBr1_critique-F.doc

63

included in Table 10.

MCKEEL	COMMENT	to	BB.5.4	Summary	of	Intakes	of	Radioactive	Materials:

[1.	That	would	imply	the	time	involved	in	moving	uranium	around	the	site	

would	be	less	than	5%	of	the	time	it	was	in	the	betatron	building]	-- I	strongly	

disagree with	this	analysis. NIOSH	would	have	to	assign	a	time	interval	to	each	

task	in	handling	and	moving	MCW	uranium	from	the	shipping	truck	or	rail	car	

to	the	two	Betatron	facilities.	The	Old	and	New	Betatron	buildings	at	GSI	are	

approached	using	different	types	of	rail-based	systems	(engine	and	regular	

flat	cars	for	Old	Betatron)	and	electric, shorter	“transfer” cars	for	the	New	

Betatron.	

•		Other	steps	for	which	time	spent	needs	to	be	allocated	include:	(a)	

unloading	MCW	U-238	metal	forms	from	the	rail	cars	or	truck,	(b)	picking	up	

the	uranium	with	a	fork	lift	or	chain	and	crane,	(c)	moving	from	the	loading	

dock	to	the	weighing	station,	(d)	replacing	the	uranium	on	a	regular	flat	car	or	

on	a	transfer	car,	(e)	driving	the	train	or	transfer	car	from	the	loading	dock	

past	the	mile	long foundry	and	buildings	5	through	10,	(f)	unloading	at	the	

Betatron	buildings,	(g)	pickup	and	positioning	with	the	overhead	cranes	in	the	

OBB	and	NBB shooting	rooms. The	aggregate	time	that	would	be	required	for	

those	steps	has	not	been	calculated	by	either	NIOSH	or	SC&A	to	my	knowledge.	

I	believe	that	all	these	steps	would	obviously	consume	far	more	than	5%	of	the	

time the	uranium	was	inside	the	Betatron	buildings.

[2.	More	likely,	the uranium	would	be	moved	some	distance	with	each	

conveyance	before	being	transferred	to	another	conveyance	and	airborne	

activity	would	thus	not	accumulate	in	a	single	area]	-- This	type	of	reasoning	is	

spurious	and	incorrect.	Successive	runs	of	MCW	uranium	over	the	13	year	AEC	

operational	period	at	GSI	(1952-1966)	would	result	in	multiple	cycles	of	

resuspension	and	settling	and	buildup	all	along	the	uranium	transport	

pathway.	So,	YES,	uranium	dust	would	accumulate	in	many	different	areas	and	

probably	form	a	continuous	Ur-238	radiocative	dust	accumulation	all	along	

the	transport	pathway.	NIOSH	failed	to	calculate	a	uranium	load	along	any	

segment	of	the	GSI	Ur	transport	path	outside	of	the	Betatron	buildings.	No	

radiologic	surveys	of	this	more	than	mile	long,	multi-stop	and	go	uranium	

transport	pathway	exist	(were	not	collected	by	GSI	or	DOE	1993	or	others).

[3.	while	the	uranium	is	being	moved	on	a	conveyance,	additional	airborne	

activity	could	be	produced	by	vibrations.	Again	however,	this	would	not	occur	in	

a	single	area	but	rather	all	along	the	path]	-- The	analysis	is	incorrect.	The	Ur	

transport	path,	with	passage	of	years,	would	become	“a	single	area,”	a	

rectangle	perhaps	1+	mile	long	by	30	yards	wide.

[4.	With	these	uncertainties	in	mind,	this	estimate	will	assume	workers	are	

exposed	to	uranium	airborne	contamination	as	if	the	uranium	were	handled	

100%	of	the	uranium	contract	time.]	-- This	treatment	is	claimant	favorable	
DWM_GSIappBBr1_critique-F.doc

64

and	should	increase	external	and	internal	doses	(important	for	later	PER).

[5.	A	resuspension	factor	of	1E-5	m-1	was	then	used]	-- McKeel	has	discussed	

the	fact	in	white	papers	(one	on	TIB-70	itself	at	GSI)	that	a	more	realistic	and	

claimant	favorable	value	for	the	resuspension	factor	would	1	x	10-4 per	meter	

squared,	as	was	once	advocated	by	John	Mauro	of	SC&A.

[6.	The	ingestion	intake	was	calculated	using	OCAS-TIB-009]	-- NIOSH	resorts	

automatically	to	invoking	OCAS-TIB-009	to	assign	uranium	ingestion	intake	

values	in	the	absence	of	measured	site	data on	ingestion.	Many	GSI	workers,	as

did other	steel	plant	workers, testified	they	ate	their	lunches	in	the	plant	and	

in	the	Betatron	buildings.	We	have	company magazine	photos	of	this	practice	

ating	lunch	on	GSI	castings.	NIOSH	has	no	realistic	measured	ingestion	data	for	

any	GSI	worker.	Thus,	it	is	impossible	to	state	with	known	certainty	the	

assumptions	in	TIB-009	have	any	relationship	to	GSI	reality. Ingestion	dose	is	

probably	underestimated	by	the	routine uncritical	use	of	TIB-009.

BB.6 Residual Contamination 

After uranium operations ended at GSI, uranium contamination may have been left behind on 

surfaces. This residual contamination would cause external and internal doses to be received 

by workers even after the uranium work ended. In 1989 the old betatron building was 

surveyed to check for residual contamination (ORNL 1990). Later the new betatron building 

was surveyed and in 1993, a short decontamination effort removed any detectable 

contamination (DOE 1994). A residual contamination period for GSI is designated from 

7/1/1966 to 12/31/1993 (DOE web site). 

MCKEEL	COMMENT	to	BB.5.4	Residual	Contamination (part	1,	page	20):	Mr.	

Allen	and	the	TBD-6000	WG	all	have	referred	to	December	31,	1992 rather	

than	1993	as	being	the	end	of	the	GSI	residual	contamination	period.	Those	

WG	and	full	Board	transcripts	that	contain	the	“1992	error”	need	to	be	

corrected.	December	31,	1993	is	the	correct	date when	DOE	completed	its	Old	
DWM_GSIappBBr1_critique-F.doc

65

Betatron	building	cleanup	work.

[Page 30 of 38]

The internal dose estimate for the operational period included inhalation and ingestion 

intakes from surface contamination. With no indication of a decontamination effort or a 

cleanup, it is assumed that these levels of inhalation and ingestion continued into the residual 

period. This level is assumed from 7/1/1966 to 12/31/1967. After that, [1. the level is 

assumed to decrease at a rate of 0.00067 per day in accordance with ORAUT-OTIB0070]. The calculated values by year are included in Table 11. 

Using contamination levels derived in section BB.5.4 and the conversation factor contained 

in Battelle-TBD-6000, an annual photon and beta dose can be calculated to be 0.173 mR/yr 

and 16.7 mrad/yr respectively. However, a 1989 survey of the old betatron also included a 

dose rate survey of the building. [2. While most measurements were consistent with 

background levels of radiation, a vacuum cleaner in one corner measured 90 uR/hr on 

contact. This represents a radiation dose higher than that from the surface 

contamination levels calculated above.] It is possible some uranium was vacuumed and 

thus concentrated in this localized area causing a localized dose rate higher than what would 

be expected if the contamination were distributed. Also, in that scenario, the depletion factor 

from ORAUT-OTIB-0070 would not be applicable. In order to account for this possibility, 

this estimate assumes [3. someone is in contact with this vacuum cleaner for 3250 hours 

per year, resulting in an annual dose of 292.5 mR]. This value will be assigned to each 

year of exposure during the residual contamination period as a constant distribution. The 

energy should be assumed to be 50% greater than 250 keV and 50% 30 to 250 keV. Since in 

this scenario [4. the vacuum cleaner would stop beta particles the beta dose rate is 

considered zero in the residual period]. It should be noted that this dose is more favorable 

than the combined photon and beta dose calculated from a distributed source. 

[5. Since both internal and external estimates are based on bounding scenarios, doses 

calculated will be entered into IREP as a constant].

[Page 31 of 38]
DWM_GSIappBBr1_critique-F.doc

66

MCKEEL	COMMENT	to	BB.6	Residual	Contamination:

[1.	the	level	is	assumed	to	decrease	at	a	rate	of	0.00067	per	day	in	accordance	

with	ORAUT-OTIB-0070] -- McKeel	wrote	and	submitted	to	Docket	140	and	the	

TBD-6000	WG	a	detailed	analysis	of	why	simple	exponential	or	linear	residual	

contamination	decay	functions	in	TIB-70	do	not	apply	realistically	(or	validly)	

to	the	situation	at	GSI.	The	GSI	site	expert	team	provided	voluminous	evidence	

to	the	TBD-6000 WG	to	document	that	multiple	steel	companies	conducted	

operations	involved	in	steel	making	(such	as	pickling	in	acid)	at	GSI	after	

castings	operations	ceased	in	1973	up	until	the	DOE	cleanup	of	uranium	in	the	

Old	Betatron	Building	in	1993.	Each	new	business	cycle	caused	resuspension	

and	settling	of	U-238	dust	all	along	the	uranium	transport	pathway.	TIB-70	

does	not	model	this	repetitive	cycling	of	uranium	dust	with	variable	peaks	and	

valleys	over	the	20	year residual	period.	NIOSH	chose	to ignore	all	of	McKeel’s	

input	on	TIB-70	not	being	applicable	at	GSI.

[2.	While	most	measurements	were	consistent	with	background	levels	of	

radiation,	a	vacuum	cleaner	in	one	corner	measured	90	uR/hr	on	contact.	This	

represents	a	radiation	dose	higher	than	that	from	the	surface	contamination	
DWM_GSIappBBr1_critique-F.doc

67

levels	calculated	above.]	-- The	GSI	site	expert’s	opinions	on	the	significance	of	

the	residual	high	uranium	dust	levels	in	the	vacuum	cleaner	in	the	OBB	have	

been	discussed	and	presented	in	McKeel	white	papers.	There	were	several	far	

larger	industrial	sweepers	in	use	at	GSI	in	the	plant	and	in	the	Betatron	

buildings.	Betatron	workers testified	there	were	often	inches	of	uranium	

laden	dust	on	the	floors. We	believe	the	amount	of	uranium	in	the	small	

vacuum	cleaner	was	representative	of	nothing	other	than	the	fact	that	

uranium	was	indeed	present	at	some	time in	the	Betatron	building,	a	known	

fact	not	dependent	on	the	presence	of	a	tiny	industrial	vacuum.	It	is	very	likely	

the	average	Betatron	and	transport	pathway	uranium	dust	levels	over	the	20	

year	residual	contamination	period	were	far	higher	than	in	the	small	

industrial	vacuuum	cleaner.	DOE	only	made	cleanups	of	uranium	dust	in	the	

Old	Betatron	Building	over	1	week	in	1993.	DOE	never	made	a	radiological	

survey	of	the	remainder	of	the	Uranium	transport	path.	By	1993,	the	New	

Betatron	had	been	extensively	power	washed	and	repurposed	as	classrooms.

[3.	someone	is	in	contact	with	this	vacuum	cleaner	for	3250	hours	per	year,	

resulting	in	an	annual	dose	of	292.5	mR]	-- As	analyzed	in	comment 2	of	this	

section, the	GSI	site	expert	team	believes	use	of	the	uranium	concentration	in	

the	small	vacuum	at	the	end	of	the	residual	period	is	spurious,	an	

underestimate	that	is	claimant	adverse,	not	claimant	favorable.

[4.	the	vacuum	cleaner	would	stop	beta	particles	the	beta	dose	rate	is	

considered	zero	in	the	residual	period]	-- What	does	“stop	beta	particles”	

mean?	Does	it	mean	“end	the	passage	of,” or	“act	as	a	barrier	to,”	or	some	

different	meaning? Allen	needs	to	clarify	this	point	in	the	text.

[5.	Since	both	internal	and	external	estimates	are	based	on	bounding	scenarios,	

doses	calculated	will	be	entered	into	IREP	as	a	constant]	-- The	meaning	of	

“bounding	scenarios” is	unclear.	Bounding	scenario	is	an	arbitrary construct	

not	included	in	the	EEOICPA	Act.	The	standard	is	both	internal	and	external	

radiations	doses need	to	be	determined	“for	all	workers	for	all	types	of	cancer	

with	sufficient	accuracy.”	It	is	not	clear	to	the	SINEW	GSI	site	expert	team	that	

NIOSH	has	met	this	test. Also,	what	does	“as	a	constant”	mean	- constant	dose?

[Page 32 of 38]

MCKEEL	PRELIMINARY	COMMENT	ABOUT	REFERENCES:	I	have	added	

numbers	to	Dave	Allen’s	References	to	facilitate	my	commentary	about	

individual	citations	at	the	end	of	this	section.

BB.7 References 

1. AEC 1962, Atomic Energy Commission, Application for Byproduct Material License with 

Attachments, ML093431334, SRDB 102269, March 7, 1962. 
DWM_GSIappBBr1_critique-F.doc

68

2. AEC 1962a, Atomic Energy Commission, Inspection Compliance report, General Steel 

Industries, License number 12-8271-1, ML093431295, SRDB 102258, November 21, 1962. 

3. DCAS 2011, Division of Compensation Analysis and Support, Battelle-TBD-6000 

Appendix BB General Steel Industries, Dose Estimates for Portable Radiography Sources, 

August 2011, http://www.cdc.gov/niosh/ocas/pdfs/dps/dc-gsidpradsrc0811.pdf 

4. DCAS GSI web page, Division of Compensation Analysis and Support web page 

providing various white papers pertaining to GSI. http://www.cdc.gov/niosh/ocas/gsi.html 

5. DOE 1991, U.S. Department of Energy, Office of Environmental Restoration, Designation 

Summary for the Granite City Steel Division in Granite City, Illinois, September 1991 

6. DOE 1994, Department of Energy, Certification Docket for the Remedial Action 

Performed at the Granite City Site in Granite City, Illinois, June 1993, September 1994 

7. DOE Web Site, DOE Office of Health, Safety and Security, EEOICPA web site. 

http://www.hss.energy.gov/healthsafety/fwsp/advocacy/faclist/findfacility.cfm 

8. ICRP 1996, International Commission on Radiological Protection . “Conversion 

Coefficients for use in Radiological Protection against External Radiation,” ICRP Publication 

74. Annals of the ICRP, 26 (3/4). Tarrytown, NY: Elsevier Science, Inc. 

9. Kleber 1962, Letter from L.A. Kleber to James Mason, ML093431291, SRDB 102254, 

March 7, 1962 

10. Landauer 1964, 1964 Landauer film badge reports for GSI, 1964 

11. Landauer 1965, 1965 Landauer film badge reports for GSI, 1965 

12. Landauer 1966, 1966 Landauer film badge reports for GSI, 1966 

13. Landauer 1967, 1967 Landauer film badge reports for GSI, 1967 

14. Landauer 1968, 1968 Landauer film badge reports for GSI, 1968 

15. Landauer 1969, 1969 Landauer film badge reports for GSI, 1969 

16. Landauer 1970, 1970 Landauer film badge reports for GSI, 1970 

17. Landauer 1971, 1971 Landauer film badge reports for GSI, 1971 

[Page 33 of 38]

18. Landauer 1972, 1972 Landauer film badge reports for GSI, 1972 

19. Landauer 1973, 1973 Landauer film badge reports for GSI, 1973 

20. Mallinckrodt 1958-1965, Mallinckrodt Chemical Works, Various Purchase Orders. U-
DWM_GSIappBBr1_critique-F.doc

69

52538-C, U-57809-M, U-55125-M, U-00045-M, U-00211-M, U-00339-M, U-00399-M, U00497-M, 00623-L, 1958 through 1965. 

21. Minutes 2007, Meeting Minutes, Dr. Robert Anigstein of Sanford Cohen & Associates 

(SC&A) Interviewing Former Employees of General Steel Industries (GSI), October 9, 2007 

22. NCC 1962, Nuclear Consultants Corp., Area Radiation Survey of the Radiographic 

Exposure Facility at General Steel Industries, ML093431294, SRDB 102257, August 14, 

1962 

23. ORAU Collection, Oakridge Associated Universities, Radium 226 Source Picture, 

Oakridge Health Physics Historical Instrumentation Museum Collection, 

http://www.orau.org/ptp/collection/Sources/radiumradiog.htm 

24. ORNL 1990, Oak Ridge National Laboratory, Results of the Radiological Survey at the 

Granite City Steel Facility, Granite City, Illinois. ORNL/RASA-89/10, July 1990 

25. Putzier 1982, Putzier, E. A., The Past 30 Years at Rocky Flats: A Summary of 

Experiences and Observations at Rocky Flats Plant Over the Past 30 Years with Emphasis on 

Health and Safety, Rockwell International Energy Systems Group, Rocky Flats Plant, 1982. 

26. SC&A 2014, Sanford Cohen & Associates, Update of Doses from External Exposure at 

GSI, January 12, 2014 

27. SC&A 2011, Sanford Cohen & Associates, Update on the Use of Sealed Radioactive 

Sources at General Steel Industries, October 2011 

28. SC&A 2008, Sanford Cohen & Associates, Review of “Site Profiles for Atomic Weapons 

Employers That Worked Uranium and Thorium Metals – Appendix BB: General Steel 

Industries,” Battelle-TBD-6000, Appendix BB, Rev. 0, April 2008 

29. Schuetz 2007, Jack G. Schuetz, Correspondence with Dr. Samuel Glover, May 2007 

30. Simmons Cooper 2006, LLC, GSI Affidavit Testimony, July 7, 2006 

31. MCNP, Los Alamos National Laboratory, MCNPX version 2.6, 2.7 and MCNP6.

Transcript 2009, Transcript of the TBD-6000/6001 Work Group of the Advisory Board on 

Radiation and Worker Health, October 14, 2009

MCKEEL	COMMENTS	to	the	References:

•	References	1,	2	and	9 are	from	McKeel	FOIA	NRC	2010-0012	and	should	be	so	

referenced.

•	Reference	4 should	include	this	in Docket	140.

•	References	5	and	6 are	incomplete:	where	are	they	published?	Are	they	

FUSRAP	documents,	and,	if	so,	what	are	the	document	numbers,	and	what	are	

the	URL	hyperlinks	to	retrieve	them	from	a	particular	database?

•	References	10	through	19:	These	references	are	very	incomplete	and	

inadequate.	Where	can	they	be	found?	Are	they	referenced	in	SRDB?	Is	there	a	
DWM_GSIappBBr1_critique-F.doc

70

URL	link	to	them?	What	is	the	contract	number	under	which	they	were	

obtained?	What	is	their	source?

•	Reference	20:	Where	can	these	MCW	purchase	orders	be	found?	Are	they	

FUSRAP	records,	and,	if	so,	what	is	their	number	and	URL	linkage?	Do	they	

have	SRDB	numbers?

•		Reference	21:	What	is	the	URL	link	to	download	this	document?

Reference	25:	This	is	an	inexact	and	incomplete	reference	for	the	Putzier	

effect.	It	is	a	long	book,	and	thus	the	page/s	on	which	the	Putzier	effect	is	

described	should	be	given.	It	will	otherwise	be	impossible	for	persons	to	find	

this	specific	reference.	And	is	it	true	the	effect	is	not	also	described	in	a	peerreviewed	journal	paper? What	is	that	reference	if	it	exists?

References	26	through	30:	Where	are	the	URL	links	to	access	these	5	papers?

[Page 34 of 38]

ATTACHMENT A – Dose Estimate for Walking Through Radiography Area

A picture of a circle designating boundary area. Line dissecting the circle represents the path 

of travel.

The dose received by an individual walking through a radiography area can be calculated 

using the diagram provided above. The source is represented by the center of the circle while 

the circle represents the delineated boundary of the radiography area. The horizontal arrow 

represents the path taken by the individual through the delineated area. The closest distance 

the person come to the source is indicated as Ro and the distance from the source at any time 

t is R(t). 

The distance between the individual and the source can then be expressed as: 
DWM_GSIappBBr1_critique-F.doc

71

R2(t) = Ro2 + X2(t) 

Or

[Page 35 of 38]

DR(t) = DRo * Ro2 / (Ro2 + V2*t2) 

The dose received by walking through the area is then: 

Dose = 2 Dose rate at the closest point of travel times the distance at the closest point squared 

divided by the distance at the closest point squared plus the velocity of travel squared times 

time squared. The entire term is integrated from time 0 to time t then multiplied by 2 to equal 

the dose.

With t = 0 at the time the person is closest to the source and t = t when the boundary of the 

radiography area is reached. 

This equation can be approximated as: 

Dose is equal to 2 times the dose rate at the closest point of travel times distance squared 

divided by the square root of the distance squared times the velocity squared. The entire term 

is multiplied by the arc tangent of time times the square root of the distance squared times the 

velocity squared divided by the distance squared. 

The time t required to walk through the area varies as Ro changes. That is, it depends 

whether the person is walking through the middle of the area or cutting through the outer 

edge. Since DRo is the dose rate at the closest point, this too varies as Ro changes. The 

equations for both are: 

Time is equal to the square root of R prime squared times minus the distance at the closest 

point squared all divided by velocity.

The dose rate at the closest distance is equal to the dose rate at one foot divided by the 

distance at the closest point squared all times 3600 seconds per hour.

Where R’ is the radius of the delineated area and DR’ is the dose rate at 1 foot from the 

source. 

Substituting these two equations into the equation for dose and simplifying yields: 

Dose is equal to 2 times the dose rate at one foot divided by the square root of the distance 

squared times the velocity squared. The entire term is multiplied by the arc tangent of the 

square root of 1 foot squared minus the distance at the closest point squared all divided by the 

distance.

MCKEEL	FOOTNOTE:	The	text	conversion	software	has	converted	formulaic	

representation	of	the	original	Allen	AppBBr1	paper	into	plain	text	language.

MCKEEL	COMMENT	to	Attachment	A:	The	phrase	at	issue	is:	“delineated 
DWM_GSIappBBr1_critique-F.doc

72

boundary of the radiography area.” Paul	Sinn	of	St.	Louis	Testing	Company	

provided	subsequent	testimony	to	John	Ramspott	and	Dan	McKeel	during	

2013 that	indicated	there	was	a	more	rigid	inner	boundary,	mandated	by	the	

AEC/NRC,	where	the	dose	from	NDT	gamma	sources	such	as	Ir-192	might	

reach	or	exceed	100	mRem/hr.	That	boundary	also	needed	to	be	marked	by	

tape. Radiographic	NDT	service	contractors	such	as	St.	Louis	Testing	Company	

had	to	maintain	guards	constantly	at	the	100	mR/hr	inner	zone.	This	new	

information	was	passed	along	to	NIOSH	and	the	TBD-6000	WG	and	was	

incorporated	into	McKeel’s	53	GSI	white	papers.

[Page 36 of 38]

ATTACHMENT B – Surrogate Air Data for Handling Uranium Metal

Battelle-TBD-6000 contains an analysis of surrogate air sample data for a number of 

common tasks associated with uranium metal. One task not covered is the handling and 

movement of cold uranium metal. To fill this void, NIOSH reviewed air sample data for a 

number of sites and combined them into this analysis. 

Most active manipulation of uranium metal requires the metal to be heated. Typically 

uranium in these processes is heated to well over 1000 degrees Fahrenheit. At these high 

temperatures, the uranium metal oxidizes readily forming a loose oxide layer that can easily 

create airborne contamination. An exception to heating uranium metal during operations is 

machining. When uranium metal is machined or cut, it is not normally preheated. Rather, the 

area being cut is cooled with machine oil, water or some other coolant. This not only reduces 

the release of airborne activity, but also cools the metal to prevent fuming. 

In all cases, however, the metal is moved by various means to the furnace or equipment prior 

to working. The movement of cold uranium metal presents such a low potential for airborne 

uranium that very few air samples were ever taken. Those that were, are often taken while 

other operations are also occurring causing the air in the vicinity to be contaminated by the 

nearby operations. Therefore, samples intended to be representative of the operation at GSI 

must consider not only the type of operation but the potential interferences in the vicinity. 

The data set used in listed in Table B.1. The samples include data collected at several 

facilities and cover operations involving three forms of uranium metal: slugs, billets and 

dingots. 

Slugs were typically 8 inches long and approximately 1 inch diameter weighing 

approximately 4 pounds. They were intended to be used as fuel in plutonium production 

reactors. Operations associated with the selected samples primarily involved moving slugs 

into or out of a container. 

A billet is a generic metallurgical term used to describe a semi-finished piece of metal. In 

uranium fuel fabrication, it is a piece of uranium metal that was originally cast into an ingot 

and rolled into a smaller dimension using a blooming mill. The billet would later be further 

rolled to a finished product using a rolling mill. The billets associated with the data found for 

this report were approximately 7 inches in diameter and 20 inches long. This would result in 
DWM_GSIappBBr1_critique-F.doc

73

a billet weighing approximately 525 pounds. 

A dingot (direct ingot) is a term used at Mallinckrodt to describe an ingot made directly from 

the metal reduction process. The alternative procedure was to remelt several derbies and cast 

them into ingots. The dingot is approximately 18 inches in diameter and 18 inches long 

weighing approximately 3300 pounds. 

Figure 1 graphically depicts the average airborne value associated with handling each form of 

uranium found in Table B.1.

[Page 37 of 38]

Figure B.1 – Average Airborne Activity while Handling Cold Metal (dpm/m3)

Graph showing average airborne activity from handling slugs, billets and dingots

The figure is arranged from left to right by the weight associated with each form of metal. No 

specific pattern can be seen that would indicate one form of metal creates higher airborne 

activity than another. Based on the data reviewed, however, the levels of airborne activity are 

relatively low and can be represented by a fairly consistent quantity regardless of the form of 

the metal. Therefore, to establish the range of exposures associated with the movement of 

cold uranium metal, all the data in Table B.1 were combined into a single distribution of 

airborne activity. 

Table B.1 contains the results for the samples utilized in this report. The attachment includes 

the Site Research Database document number and page number where the sample was 

located. It also includes the site from which the samples were collected as well as the type of 

metal and the date the sample was collected. A few of the values are listed as “nd” which 

represents a “none detectable” sample. 

The samples were analyzed assuming they can be represented as a lognormal distribution. 

The resulting distribution has a geometric mean of 17.5 dpm/m3 with a geometric standard 

deviation of 2.29. This distribution results in a 95th percentile value of 68.7 dpm/m3. This is 
DWM_GSIappBBr1_critique-F.doc

74

the value NIOSH intends to use for the assessment of inhalation exposure to uranium at GSI. 

[Page 38 of 38]

MCKEEL	COMMENT	TO	ATTACHMENT	B: These	data	were	the	subject	of	

extensive	discussion	at	TBD-6000	WG	meetings.	Once	again,	AppBBr1	ignores	

McKeel’s	main	objections	to	the	use	of	this	specific	surrogate	data:	(a)	GSI	did	

not work	with	uranium	slugs,	hence	the	slug	facilities	are	per	se not	similar	

and	thus	do	not	meet	Board	surrogate	data	criteria;	(b)	much	higher	air	

concentrations	of	uranium	were	documented	in	Adley	1952	(Hanford	melt	
DWM_GSIappBBr1_critique-F.doc

75

plant)	among	the	crews	that	unloaded	railroad	cars.	The	airborne	

concentrations	were	so	high	that	some	workers	had	to	be	placed	on	short	

shifts	to	avoid	exceeding	permissible	uranium	intake	exposure	limits.	Mr.	

Allen	ignores	these	discussions	and	McKeel’s	white	paper	on	the	Adley	1952.

MCKEEL	SUMMARY	COMMENT	ON	THE	ENTIRE

GSI	APPENDIX	BB	REV	1	DOCUMENT

•	Following	the	release	of	Appendix	BB	Rev	0	in	June	2007	Dan	McKeel,	who	

would	later	assume	the	role	of	GSI	SEC-00105	co-petitioner,	and	GSI	site	

expert	John	Ramspott,	filed	separate	strongly	critical	analyses	of	this	

scientifically	flawed	13	page	TBD	document.	NIOSH	promptly	posted	rebuttals	to	

both	the	McKeel	and	Ramspott	critiques.	Basically,	NIOSH	defended	everything	in	

that	initial	document,	admitting	nothing	and	declining	to	alter	anything.	This	was	

despite	the	fact	that	(a)	neutron	dose	from	the	Betatrons	was	not	addressed,	(b)	

several	radiation	source	doses	were	not	bounded,	and	(c)	there	was	no	individual	or	

site	monitoring	data	known	to	NIOSH	and	no	measured	data	at	all	in	the	literature	

for	actual	operating	Betatrons	at	the	time	Appendix	BB	Rev	0	was	released.	McKeel	

also	argued	that	Appendix	BB	Rev	0,	as	first	drafted,	was	so	scientifically	flawed	it	

should	not	be	released	or	used	for	dose	reconstructions	without	immediate	

revisions.	Again,	NIOSH	ignored	this	advice.	By	now,	in	July	2014,	seven	years	later,	

all	completed	GSI	DRs	except	for	4	covered	in	PER-24,	have	been	completed	using	

AppBBr0	dated	June	2007	without	any	interim	revisions	having	been	made.

•		In	these	early	days—2005	through	early	2008—McKeel	argued	forcefully	

that	GSI	deserved	an	83.14	self-initiated	SEC. The	fact	that	Battelle-NIOSH	had	

completed	only	a handful	of	individual	GSI	dose	constructions	by	early	2007,	despite	

there	being	hundreds	of	claims	and	cases,	supported	the	contention	that	NIOSH	was	

unable	to	complete	DRs	in	a	timely	way	and	the	site	merited	an	83.14	SEC.	However,	

for	reasons	still	not	clear,	NIOSH	avoided	making	this	well	deserved	site	declaration.

•		In	January	2007,	after	months	of	negotiations	he	initiated	with	RS	Landauer	

film	badge	company,	Dan	McKeel	obtained	year	end	film	badge	reports	on	a	

subset	of	GSI	radiographers	who	had	Landauer	weekly	film	badge	(FB)	data	

referred	to	as	Program	2084. The	GSI	FB	data	started	in	1964	and	ended	with	

1973	data.	NIOSH	contracted	with	Landauer	(a	PA-cleared	version	of	the	contract	

was	never	released)	and	obtained	a	more	complete	weekly	GSI	FB	dataset	(see	

References	9-19	on	page	68 of	this	document)	in	March	2008.	

The	need	for	NIOSH	to	incorporate	Landauer	FB	data	into	new	NIOSH	dose	

reconstruction	methods	was	the	primary	basis	for	David	Allen’s	Path	Forward	for	

GSI white	paper	in	late	2010.	Dan	McKeel	observed	the	need	for	such	a	paper	was	

persuasive	evidence	that	NIOSH	could	not	reconstruct	GSI	external	and	internal	

doses	with	sufficient	accuracy.	
DWM_GSIappBBr1_critique-F.doc

76

In	2012,	NIOSH, with	concurrence	of	the	TBD-6000	WG	Board	members	and	

SC&A, decided	that	the	relatively	higher	(10-fold	greater)	external	doses	

assigned	to	GSI	Betatron	and	isotope	radiographers	compared	to	other	

workers	in	AppBBr0	in	2007	should	be	sharply	reduced	by	approximately	9-

fold.	This	was	done	primarily	because	of	the	availability	of	Landauer	FB	data	for	this	

tiny	subset	of	109	out	of	3000	to	5000	GSI	workers.	McKeel	highlighted	this	striking	

reversal	of	external	dose	radiographer	and	other	worker	external	dosimetry	data	

between	2008	and	2012	in	his	March	15,	2012,	Powerpoint presentation	to	the	

TBD-6000	WG.	McKeel	stated	this	discrepancy	was	not	scientifically	defensible.	The	

agreement	between	models	over	time	and	between	NIOSH	and	SC&A	did	not	meet	

the	usual	standards:	(a)	±	10	to	20%	agreement	of	measured	data,	(b)	NIOSH	did	not	

have	any	measured	Betatron	photon,	electron	or	neutron	data	and	rejected	NYO4699	to	validate	the	MCNPX or	Attila (2008)	Betatron	models,	and	(c)	NIOSH	and	

SC&A	could	not	reproduce	each	other’s	modeled	data	closer	than	200%. The	2008	

Betatron	modeled	doses	by	NIOSH (1.0-6.3	R/yr)	and	SC&A	(12.4-13.6	R/yr)	varied	

by	much	more	than	this.

•		AppBBr1	is	replete	with	uses	of	GSI	film	badge	data	and	has	11	out	of	31	

total	references	devoted	to	these	records.	The	crucial	fact	that	Allen	omits	from	

AppBBr1	is	that	in	2014, based	on	Board	initiated	off	the	record	interactions	

between	the	DCAS	Director	(Stuart	Hinnefeld)	and	a	senior	vice	president	of	RS	

Landauer	(Craig	Yoder),	NIOSH	decided	to	abandon	use	of	GSI	program	#2084	film	

badge	data	altogether.	Instead,	in	a	12/19/13	memo	written	by	Dr.	James	Neton	of	

DCAS	at	the	direction	of	Stuart	Hinnefeld,	NIOSH	would	“adopt	SC&A’s	method.”	The	

Neton	memo	did	not	spell	out	what	this	referred	to	“SC&A	method”	actually	was.	

The	Neton	memo	was	first	transmitted	to	the	TBD-6000	WG	members	and	to	Dr.	

Bob	Anigstein	of	SC&A	to	insert	into	the	December	2013	GSI	issues	matrix.	

Dan	McKeel	learned	about	this	key	memo	at	a	TBD-6000	WG	meeting	and	had	to	ask	

for	a	personal	copy.	This	is	but	one	of	many	instances	where	crucial	NIOSH	

documents that	were	highly	relevant	to	GSI	were	not	provided	to	McKeel	voluntarily	

as	they	should	have	been	because	of	his	role	as	GSI	SEC	co-petitioner.	In	the	case	of	

the	Landauer	FB	data,	McKeel	initiated	the	contact	with	Landauer	and	led	to	NIOSH	

even	being	aware	of	these	key	data.	Professional	etiquette	and	fair	play	and	FACA	

mandated	transparency	and	document	sharing	provisions	all	compel	NIOSH	to	

share	information	and	records	related	to	RS	Landauer	with	McKeel.

•		In	October	2007 SC&A	held	a	group	session	to interview	GSI	radiographers	

primarily.	At	this	conference,	there	was	consensus	agreement	the	average	GSI	

work	week	should	be	changed	from	46	hours	per	week	in	AppBBr0	to	65	

hours	per	week	in	AppBBr1.	This	is	obviously	a	major	change	that	will	affect	

assigned	doses.	The	revision	in	the	average	work	week	was	not	made	until	AppBBr1	

was	issued	on	6/6/14.	McKeel,	Ramspott	and	GSI	workers	have	urged	NIOSH	to	

make	this	simple	change	in	Appendix	BB	for	years.
DWM_GSIappBBr1_critique-F.doc

77

•		Dave	Allen	fails	to	mention	in	AppBBr1	the	key	fact that	Dan	McKeel’s	FOIA	

NRC2010-0012	for	GSI	By-Products	materials	license	documents	first	revealed	

the	presence	of	two	radium-226	NDT	gamma	sources	at	the	GSI	plant	that	

were	used	with	the	fishpole	technique	through	1962	and	perhaps	for	part	of	

the	1963.	NIOSH	at	first	was	under	the	impression	the	building	6	radiography	room	

known	to	be	used	for	cobalt-60	NDT	work	was	built	in	1962.	A	highly	detailed	1957	

GSI	plant	engineering	drawing	obtained	by	GSI	site	expert	John	Ramspott	showed	

definitively	the	“radiography	room”	in	building	6	existed	in	1957.	Ramspott	

re-interviewed	GSI	workers	Dave	Woodard	and	Dan	Churovich	and	obtained	

affidavits	from	both	that	conclusively	showed	the	Building	6	inner	radiography	

room	was	built	in	1955.	Thus,	all	radium	NDT	work	done	between	1952	and	1955	

was	done	in	the	open	buildings	5	through	10.	These	two	affidavits	cast	doubt	on	the	

inner	building	walls	being	“built	out”	to	24	inches	in	1962	by	additional	layers	of	

concrete	blocks	and	sand.	Workers	present	in	1962	declared	this did	not	happen.	

•		As	a	general	comment,	there	is	a	marked	discrepancy	observed	by	the	SEC	

petitioners,	site	experts	and	workers	as	to	many	“facts”	recorded	on	paper	

that	differed	from	eye	witness	contemporaneous	observations	of	those	“on	the	

ground.” All	of	the	above	persons	have	serious	reservations	about	GSI	declarations	

of	radiation	safety	limits	never	being	exceeded,	of	an	active	safety	program	with	

yearly	written	test	for	radiographers,	and	of	affidavits	of	certain	observers	that	

agree	with	NIOSH’s version	of	the	facts,	but	which	differ	from	their	own	

observations.	Such	observations	would	include	the	presence	and	use	of	a	GSI	owned	

Ir-192	source,	which	is	recorded	in	a	1972	GSI	license	renewal	document	in	the	NRC	

FOIA	2010-0012	dataset (see	Exhibit	1).	Numerous	GSI	radiographers	testified	they	

used	an	80	curie	Co-60	source	at	GSI	between	1964-1966.	NIOSH	accepts	the	GSI	

license	data	that	shows	an	80	curie	Co-60	source	was	licensed	by	the	AEC	in	1968.	

Several	of	those	who	testified	using	the	80	Ci	source	left GSI	before 1968.

MCKEEL	EXHIBIT	1:	GSI	By-Product	Materials	License	12-08271-01,	

Amendment	No.	08,	March	15,	1972	application,	pages	1	and	2	of	2,	Page	2	

with	NRC	FOIA	document	URL:	ML093480290	available	on	the	NRC	ADAMS	

website. PAGES	78-80.

MCKEEL	EXHIBIT	2:	A	listing	of	Daniel	W.	McKeel,	Jr.,	MD	Docket	140	GSI	white	

paper	publications.	From	GSI	SEC-00105	admininstrative	review	pages 81-87.

Respectfully	submitted,

Daniel W. McKeel, Jr., MD July	15,	2014

Cofounder	SINEW E-mail:	danmckeel2@aol.com

GSI,	Dow	and	TCC	SEC	co-petitioner Mail:	PO	Box	15/#7	CR301A,

Phone:	(573)	323-8897 Van	Buren,	MO	63965-0015

Fax:	(573)-323-0043